RAYALA SEEMA ENTERPRISES Vs. STATE OF ANDHRA PRADESH

JUDGEMENT

(1.) THESE TRCs are filed against the common order in Tribunal Appeal Nos. 932 and 933/97 dated 9.4.1990. By the Order in the appeal, the Tribunal remanded the matter to the Joint Commissioner. On the last occasion when the matter was posted before us, we wanted the Special Government Pleader for Taxes to ascertain whether any notice was issued pursuant to the remand order proposing to reconsider the matter. The learned Special Government Pleader has now represented that neither a notice was issued nor any order was passed and the record does not contain any material in this respect. The learned Government Pleader contended that no TRCs lie against remand order. However, it is not necessary to decide that issue. Since 8 years have elapsed and the period of limitation has already expired under Section 24A of the APGST Act to pass any order pursuant to the remand, the Joint Commissioner cannot initiate any proceedings. The TRCs are therefore closed as no orders are necessary. No costs.