ORDER H. S. KAMATH, PRESIDENT. - Of the two grounds on which revision is sought, only the first need be considered at this stage. The Sales Tax Commissioner has held that Section 22(6) of the Act does not permit him to review an order passed by his predecessor. The point for decision is whether this view of the law is correct. 2. Section 22(6) reads as follows :- "Subject to rules made under this Act, any person appointed under Section 3 may review any order passed by him." The only relevant portion from Rule 59 of the rules, pertaining to review, is as follows :- "Any person considering himself aggrieved by an order passed under the Act or the Rules made thereunder by any person appointed under Section 3..............may apply for a review of the order to the Officer who passed the order." Now, Section 3 mentioned in Section 22(6) as well as in Rule 59 reads as follows :- "3. (1) The Provincial Government may appoint any person to be a Commissioner of Sales Tax, and such other persons under any prescribed designations to assist him as it thinks fit. (2) Persons appointed under sub-section (1) shall, within such areas as the Provincial Government may specify, exercise such powers as may be conferred and perform such duties as may be imposed by or under this Act. * * * * 3. In none of the provisions in the Act and the Rules pertaining to review, extracted above, has any distinction been made between an order passed by an officer and an order by his predecessor-in-office. In this respect, the position is quite different from what one finds in analogous provisions, say, in the Central Provinces Land Revenue Act, which seem to have influenced the Commissioner's decision. Section 40(1) of the Central Provinces Land Revenue Act, for example, reads as follows :- "The Provincial Government and every Revenue Officer may, either on his own motion or on the application of any party interested, review any order passed by himself or by any of his predecessors-in-office and pass such order in reference thereto as he thinks fit. Section 40(1) of the Central Provinces Land Revenue Act, for example, reads as follows :- "The Provincial Government and every Revenue Officer may, either on his own motion or on the application of any party interested, review any order passed by himself or by any of his predecessors-in-office and pass such order in reference thereto as he thinks fit. Provided that - (1) if the Commissioner, Settlement Commissioner, Deputy Commissioner or Settlement Officer thinks it necessary to review any order which he has not himself passed, and if an officer subordinate to a Deputy Commissioner or Settlement Officer proposes to review any order, whether passed by himself or by any predecessor, he shall first obtain the sanction of the officer to whom he is immediately subordinate; * * * *" If the intention of the Legislature in enacting Section 22(6) of the Sales Tax Act was that a distinction should be drawn between orders passed by an officer and orders passed by that officer's predecessor-in-office, there is no doubt that provision would have also been made regarding the circumstances in which a predecessor's order could be reviewed, as has been done in the case of the Land Revenue Act. Otherwise, there is every danger of the provision for review being largely nullified by changes taking place in the office of the Commissioner or other incumbent, from time to time - a contingency that the Legislature would, without doubt, have foreseen. And it may safely be assumed that no Legislature would knowingly or willingly countenance the possibility of any of its enactments being reduced to a nullity. But, as it actually happened, however, the Legislature provided neither for mention of the officer's predecessor-in-office, nor naturally of the circumstances in which review of the predecessor's order was permissible. The implication of Section 22(6) therefore would be to construe "the person" referred to therein by office or by designation and not by name. In other words, all that it means in the context of the present case, is that "the Commissioner may review any order passed by the Commissioner." If, for example, A has been succeeded in office by B, B is competent to review an order passed by A. B's powers of review are not restricted to reviewing orders passed by B alone. 4. 4. For the reasons given above, I hold that the Commissioner has taken an incorrect view of the legal position and I, therefore, set aside his order and direct that he should now dispose of, on merits, the application for review made to him. Ordered accordingly.