Duplicated sales tax demand on the same turnover is unenforceable after revised assessment fixes liability under the state regime.

Where a revised assessment brought the entire turnover under the Andhra Pradesh General Sales Tax Act and the appellate order confirmed that position, the same turnover could not be subjected again to recovery under an earlier Central Sales Tax Act demand. The duplicated tax enforcement was therefore unsustainable, and the garnishee notice issued to recover that demand could not be maintained. The operative point is that once tax liability has been determined on the revised assessment for the relevant turnover, recovery cannot proceed on a parallel demand for the same turnover under a different regime.

---

---

Issues: Whether the demand sought to be enforced under the Central Sales Tax Act, 1956 could survive after the turnover had been brought under the Andhra Pradesh General Sales Tax Act, 1957 by the revised assessment order, and whether the garnishee notice issued for recovery of the same tax was liable to be quashed.

Analysis: The revised assessment order brought the entire turnover under the APGST regime and the tax liability was determined accordingly, with the appellate order confirming that position. Once the same turnover stood subjected to tax under the APGST Act, the respondent could not again proceed to enforce the earlier CST demand on the very same turnover. Recovery action founded on the duplicated demand was therefore unsustainable, and the garnishee notice issued for that purpose could not be maintained.

Conclusion: The demand under the Central Sales Tax Act, 1956 was held unenforceable against the petitioner for the same turnover, and the garnishee notice was quashed.

---