Revisional power barred on issues already decided by the Appellate Tribunal, preventing reopening of concluded sales tax disputes.

Section 20(2A) of the Andhra Pradesh General Sales Tax Act, 1957 bars suo motu revisional power under section 20(1) or 20(2) where the same issue is already subject to appeal before the Appellate Tribunal or has been decided by it. The provision prevents reopening a concluded controversy, and the attempted notice seeking to revisit the branch transfer treatment as inter-State sales was therefore outside revisional jurisdiction. The notice was liable to be quashed.

---

---

Issues: Whether the Commissioner could exercise suo motu revision and issue a show-cause notice under section 20(2A) of the Andhra Pradesh General Sales Tax Act, 1957 in respect of an issue already decided by the Appellate Tribunal under section 21 of the Act.

Analysis: Section 20(2A) expressly bars the exercise of revisional power under section 20(1) or section 20(2) in respect of any issue or question that is the subject-matter of an appeal before the Appellate Tribunal, or that has already been decided on appeal by the Appellate Tribunal. The disputed notices sought to reopen the same controversy concerning treatment of branch transfers as inter-State sales, which had already been adjudicated between the parties in earlier proceedings. On that construction, the revisional authority could not invoke section 20(2A) to revisit the concluded issue, and the High Court was right in quashing the notice.

Conclusion: The notice was barred by section 20(2A) and the challenge to it failed.

---