Revisional jurisdiction under sales tax law is limited to subordinate authorities; revision by a Deputy Commissioner was invalid.

Revisional power under section 20(2) of the Andhra Pradesh General Sales Tax Act, 1957 extends only to orders passed by authorities subordinate to the revising authority, as determined by Rule 44A of the Andhra Pradesh General Sales Tax Rules, 1957. A Deputy Commissioner could not revise an assessment order that was not made by a subordinate authority within that hierarchy. The revisional order was therefore without jurisdiction and invalid, and the assessment consequences based on that revision could not survive.

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Issues: Whether the revisional authority had jurisdiction under section 20(2) of the Andhra Pradesh General Sales Tax Act, 1957 to revise the assessment order passed by an authority not subordinate to it.

Analysis: Section 20(2) confers revisional power only in respect of orders passed by authorities subordinate to the revising authority. Rule 44A of the Andhra Pradesh General Sales Tax Rules, 1957 specifies the hierarchy of authorities deemed subordinate for the purpose of revisional power. On that scheme, a Deputy Commissioner could not exercise revision over an assessment order passed by the consequential order of an Appellate Deputy Commissioner, since the order sought to be revised was not one passed by a subordinate authority within the meaning of the provision and the rule.

Conclusion: The revisional order was without jurisdiction and was invalid.

Final Conclusion: The connected assessment consequences based on the invalid revision could not survive, and the writ petitions succeeded.

Ratio Decidendi: Revisional power under section 20(2) of the Andhra Pradesh General Sales Tax Act, 1957 can be exercised only over orders of subordinate authorities as defined by the applicable hierarchy rule.

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