P GOVINDA SETTY SON AND CO Vs. DEPUTY COMMISSIONER OF COMMERCIAL TAXES BANGALORE DIVISION GANDHINAGAR

JUDGEMENT

(1.) In these four writ petitions, the two petitioners who are registered dealers under the Karnataka Sales Tax Act have challenged the notices dated 7th June, 1980, issued by the Deputy Commissioner of Commercial Taxes, Bangalore Division, Bangalore, proposing to revise the orders of assessment for the periods from 1st April, 1970, to 31st March, 1971, and 1st April, 1971, to 31st March 1972, in relation to the two petitioners for the common periods as per annexures E and F.

(2.) The Deputy Commissioner on a perusal of the revision orders dated 10th June, 1975, in the two assessees' cases, passed by his predecessor, has sough to revise the same and to bring their purchase turnover in paddy to tax under section 6 of the Act, for the two periods in question.

(3.) By order dated 10th June, 1975, the Deputy Commissioner had set aside and cancelled the orders passed by the assessing authority in so far as the levy of tax on purchase turnover in paddy was concerned, for the two periods. The Deputy Commissioner, in the said order, while exempting the purchase turnover of paddy, had observed as follows :