K. S. PUTTASWAMY, J. ( 1 ) ON 16. 8. 1978 the Addl. Asst. Commercial Tax officer (Intelligence) davanagere respondent No. 2 (hereinafter referred to as the ACTO) searched the business premises of the petitioner, who is a registered dealer under the provisions of the Karnataka Sales Tax act, 1957 (hereinafter referred to as the Act) and seized certain account' books and documents and issued an order on the same day (Ex-A) to that effect under S. 28 (3) of the Act. On 21. 8. 1978 the same officer has collected a sum of Rs. 10,464 from the petitioner as taxes due for the assessment years 1976-77 and 1977-78 and a sum of Rs. 5,000 as composition fee under S. 31 of the Act. In this petition under art. 226 of the Constitution, the petitioner has challenged the order made by the ACTO on 16. 8. 1978 (Ex.-A ). ( 2 ) THE petitioner claims that the acto was not authorised by law to search his premises and seize the documents, levy taxes, collect composition fee. Elaborating this, the petitioner contends that an 'additional' Assistant commercial Tax officer is not an Asst. Commercial Tax Officer authorised by the Act. ( 3 ) AT the hearing, the petitioner has also urged that under S. 3b (3a) of the Act, the Commissioner had not authorised the ACTO to search and seize his business premises for which reason his actions were unauthorised. ( 4 ) SRI Abbigeri Kalleshappa, teamed counsel for the petitioner, contends that an 'additional' Assistant Commercial Tax officer is not an Assistant commercial Tax officer, on whom only the Act has conferred powers of an Assistant Commercial Tax officer and, therefore, the actions of the ACTO were unauthorised and illegal. In support of his contention sri Kalleshappa strongly relies on a ruling of the Andhrapradesh High court in Addl. Commr. of IT. , A. P v. I. T. AT. (1 ). ( 5 ) SRI S. V. Narasimhan, learned high Court Government Pleader appearing for respondents contends that an additional Assistant Commercial Tax officer is also an Assistant Commercial tax Officer and the former can oxer cise all the powers of the latter under the, Act. if authorised by the Commissioner under S. 3b (3a) of the Act, as in the present case. if authorised by the Commissioner under S. 3b (3a) of the Act, as in the present case. In support of his contention Sri Narasimhan strongly relies on the Division Bench rulings of this Court in Haji M. P. Mohammad v. Sheik Ahmed (2) and Ganesh Rao v. Sarphina D' Souza Bai (3 ). ( 6 ) THE word 'addition' derived from the word 'add' means adding something to an existing thing. 'additional' is an adverb of the term 'addition' ( 7 ) AS a rule, additional officers are appointed to attend to extra or additional work of an office that cannot be performed by the incumbent of that office. In law the position of an additional officer is that of the very officer that holds the office. In this of an additional Assistant Commercial tax officer will also be an Assistant Commercial mercial Tax officer of the area or class of dealers, if authorised by the Commissioner under S. 3b (3a) of the act. ( 8 ) THE power to appoint an Assistant Commercial Tax Officer comprehends in itself the power to appoim the additional Assistant Commercial tax Officer also. ( 9 ) ON any legal principle, it is difficult to hold that an additional Assistant Commercial Tax Officer is not an Assistant Commercial Tax Officer. ( 10 ) IN Haji M. P. Mohammad's (2) and Ganesh Rao's (3) cases, this Court was examining a similar situation of an additional District Judge exercising the powers of a District Judge on whom only power to decide cases had been conferred by the Rent Control act. On such an examination, this court found that an additional District judge was also a District Judge of the area and the power exercised by the former was legal and valid. On the principles enunciated in Haji M. P. Mohammads (2) and ganesh Rao's cases, (3) which govern the question that arises in the case, it is difficult to uphold the contention of sri Kalleshappa. ( 11 ) SRI Kallqshappa relied on S. 2 (16) of the Income Tax Act, which defines the term 'commissioner' as including an 'additional Commissoner' to contend that an additional Assistant Commercial Tax Officer cannot be be an Assistant Commercial Tax officer. ( 11 ) SRI Kallqshappa relied on S. 2 (16) of the Income Tax Act, which defines the term 'commissioner' as including an 'additional Commissoner' to contend that an additional Assistant Commercial Tax Officer cannot be be an Assistant Commercial Tax officer. ( 12 ) IN my view, an additional Commissioner has been included in the term 'commissioner' exabundanti cautela to repel any possible and plausible contention in that behalf and not for the reason that there is merit in that legal contention. In any view, the provisions of the Act cannot be interpreted with reference to the provisions found in the Income Tax Act. ( 13 ) IN Addl. C. I. T, A. P's case, (1) the Andhra Pradesh High Court has interpreted the provisions of the Act without examining or expressing any opinion on the correctness of the contention urged before me. In this view the ratio in Additional Commissioner of Income Tax A. P. 's case does not really bear on the point. ( 14 ) AT the hearing Sri Narasimhan has placed before me the notification dt. 1. 2. 1977 issued by the Commissioner of Commercial Taxes conferring power on the Assistant Commercial tax Officer (Intelligence) Davanagere to exercise the powers over the entire district of Chitradurga. ( 15 ) IN view of the aforesaid notification and the construction placed bv me earlier, the ACTO was competent to search the premises and seize the documents from tne petitioner on 16. 8. 1978. ( 16 ) ON the above discussion, it follows that the order made by the acto on 16. 8. 1978 does not suffer from any error of jurisdiction or manifest illegality justifying this Court's interference under Article 226 of the Constitution. ( 17 ) AS the only contention urged for the petitioner fails, this writ petition is liable to be dismissed. I, therefore, dismiss this writ petition and discharge the rule issued in the case. But, in the circumstances of the case, I direct the parties to bear their own costs. --- *** --- .