JUDGMENT RAJU, J. - The above tax appeals are dealt with together since they are inter-related and concern not only the same assessee but relate to two different orders passed in respect of the same assessment year. The appellants are dealers in groundnut oil and oil cake at Kavandapalayam in Salem district. For the assessment year 1975-76, the appellants returned a total and taxable turnover of Rs. 21,52,715.65 and Rs. 7,24,306.70. The place of business of the appellants was inspected on May 27, 1975, September 8, 1975 and September 22, 1975, by the inspecting officers of the department and several defects and suppressions were said to have been noticed. It appears, about 12 slips of paper were recovered and they disclosed suppression of groundnut and groundnut kernel purchased to the tune of Rs. 2,51,881.50 and sale of groundnut oil valued at Rs. 6,624. In the light of the above, after issuing due show cause notice and giving sufficient opportunity, the assessing officer determined the total and taxable turnover of the appellants at Rs. 21,22,437 and Rs. 10,96,962 respectively. The assessment was one made to the best of judgment and while levying a tax of Rs. 34,670, penalty under section 12(3) of the Tamil Nadu General Sales Tax Act, 1959, hereinafter referred to as "the Act" at one and half times tax due on the suppressed turnover was also levied. Aggrieved, the appellants filed an appeal before the Appellate Assistant Commissioner, Salem. The said appellate authority allowed the claim of the appellants in respect of the estimated sales of groundnut oil from out of inter-State purchases of kernel to the tune of Rs. 22,050 and similar estimate in respect of oil cake on the said category of purchase to the tune of Rs. 6,061. So far as the addition made on the basis of the slips to the tune of Rs. 2,55,107 as representing the first purchase of groundnut and groundnut kernel locally and 10 per cent further addition towards possible omission and suppression to the tune of Rs. 25,510 is concerned, the appellate authority confined the additions based on the slips recovered in relation to the purchase omissions of groundnut and groundnut kernels to the tune of Rs. 1,17,993.10 and the additions in excess thereof has been deleted as against the said category of turnover. 25,510 is concerned, the appellate authority confined the additions based on the slips recovered in relation to the purchase omissions of groundnut and groundnut kernels to the tune of Rs. 1,17,993.10 and the additions in excess thereof has been deleted as against the said category of turnover. Further relief was also partly granted in respect of the addition made in respect of stock variations noticed at the time of inspection made on May 27, 1975, September 8, 1975 and September 22, 1975 and the penalty was also reduced to Rs. 5,406. While matters stood thus, the Joint Commissioner invoked the suo motu powers of revision by issuing a notice dated December 9, 1981 and after considering the objections of the appellants dated January 5, 1982 and hearing their authorised representative, confirmed the proposals by bringing to assessment a turnover of Rs. 3,82,200 which represented the estimated sale of oil liable to tax at 4 per cent and a turnover of Rs. 84,210 representing the estimated sale of oil cake liable to tax at 3/4 per cent. The proposal to levy a corresponding penalty was dropped. It may be stated at this stage that the estimated sales turnover as above was arrived at by the Joint Commissioner by taking into account the actual purchase turnover of groundnut and groundnut kernel locally made but suppressed by the appellants, as found by the appellate authority itself. The Joint Commissioner was of the view that though only the purchase turnover found suppressed was subjected to tax, in the absence of proof by the appellants that the groundnut purchased had been sold as such, the normal presumption is that the appellants should have crushed them into oil and oil cake and sold the same as out of accounts and, therefore, the order of the assessing officer and that of the first appellate authority required to be revised to bring to assessment turnover of Rs. 3,82,200 relating to sales of groundnut oil that should have been obtained by crushing the suppressed purchase of groundnuts and a further turnover of Rs. 84,210 relating to sales of oil cake taxable at 3 1/2 per cent with reference to the purchase suppressions of groundnut and kernel to the tune of Rs. 1,71,993 as found by the appellate authority itself. 84,210 relating to sales of oil cake taxable at 3 1/2 per cent with reference to the purchase suppressions of groundnut and kernel to the tune of Rs. 1,71,993 as found by the appellate authority itself. The appellants have filed in the year 1982 an appeal against the said order of the Joint Commissioner dated January 25, 1982, which came to be ultimately processed and entertained by this Court on its file as T.C. No. 77 of 1984. While so, the Joint Commissioner (subsequent incumbent) once again appears to have noticed a further error in the order of the first appellate authority dated October 26, 1978 and invoked his powers of suo motu revision for the second time in respect of the very same order, and issued a notice, dated October 5, 1982 and after considering the objections and hearing the authorised representatives of the appellants, confirmed the proposals by his order, dated July 11, 1983. The above proposals which were confirmed ultimately by the Joint Commissioner related to the deletion ordered by the first appellate authority in respect of a turnover of Rs. 22,050 representing the estimated sales of groundnut oil obtainable from inter-State purchase of kernel and estimated sales of groundnut cake obtainable from the said inter-State purchase of groundnut kernel to the tune of Rs. 6,061. Aggrieved, the appellants have filed a tax case, T.C. No. 25 of 1984. Mr. E. S. Kunchithapatham, learned counsel appearing for the appellants, contended, so far as T.C. No. 25 of 1984 is concerned that (a) the exercise of suo motu powers under section 34 of the Act is hit by the prohibition contained in section 34(2)(b) of the Act in that the Joint Commissioner could not have invoked powers under section 34 of the Act when the appeal filed by the appellant in this Court against the earlier order dated January 25, 1982 was pending; and (b) there was no factual basis or legal justification for the Joint Commissioner to come to the conclusion that the groundnut kernel brought from Andhra Pradesh and claimed to have been sold to agriculturists by the appellants were really crushed into oil and sold as such along with the resultant oil cake merely because the letters sent by the department to such agriculturist-buyers were returned by the postal authorities with an endorsement that the addressees were not available at the addressees given. It was contended that at any rate there was no case for invoking suo motu powers of revision in a matter to disturb findings of fact recorded by the competent appellate authority on an appreciation of evidence. So far as T.C. No. 77 of 1984 is concerned, the learned counsel contended that (a) the Joint Commissioner could not bring to assessment for the first time turnover which was not the subject-matter of consideration by either the assessing officer or the first appellate authority, in exercise of suo motu powers; and (b) that there were no proof whatsoever that the groundnut purchases covered by the addition of Rs. 1,71,993 confirmed by the Appellate Assistant Commissioner was actually crushed and sold in the form of oil and oil cake and in the absence of reasonable and justifiable basis best judgment assessment cannot be made merely on surmises and wild guess. Mrs. Chitra Venkataraman, learned counsel for the Revenue, vehemently contended that the objection based upon section 34(2)(b) has no relevance or application to the case on hand, that the reasons assigned and findings recorded by the Joint Commissioner on merits are unassailable and well justified. It was also contended for the respondents that the turnover relating to first purchase of groundnut kernels locally was confirmed even by the first appellate authority and since the details are available on record of assessment and assessment files themselves the Joint Commissioner has chosen to draw legal inferences from the available material and it is not as though any new or irrelevant materials have been used to justify the revision of taxable turnover, on merits. The Joint Commissioner was said to have given sufficient reasons and placed reliance on relevant materials available from the relevant assessment record itself and that no exception could be taken to the orders passed by the Joint Commissioner on January 25, 1982. We have carefully considered the submissions of the learned counsel appearing on either side, in the light of some of the earlier decisions of courts referred to before us. So far as the plea based upon section 34(2)(b) of the Act is concerned, we are of the view that the embargo in that provision has no application to the case on hand. So far as the plea based upon section 34(2)(b) of the Act is concerned, we are of the view that the embargo in that provision has no application to the case on hand. Sub-section (2) of section 34 mandates that the Joint Commissioner shall not initiate proceedings against any order or proceeding referred to in sub-section (1) of section 34 if the order sought to be revised has been made the subject of an appeal to the Appellate Tribunal or of a revision in the High Court, such revision to this Court being the next available remedy in the hierarchy as against the order of the Appellate Tribunal. So far as the case before us is concerned, the order sought to be revised by the Joint Commissioner in his proceedings dated July 11, 1983, is only that of the Appellate Assistant Commissioner of Commercial Taxes, Salem dated October 26, 1978 and there is no serious dispute or controversy over the fact that the said order of the first appellate authority was neither the subject-matter of an appeal before the Tribunal nor before this Court in the form of a revision after the orders of the Appellate Tribunal. When the provisions contained in section 34(2)(b) of the Act as such do not apply on the very language of the provision, there is no room for enlarging the area of prohibition contained in section 34(2)(b) of the Act so as to cover within it cases of appeal in this Court also and that too filed against an order of the Joint Commissioner earlier passed under section 34 of the Act. No new restriction or category of prohibition could be read into section 34(2)(b) by implication and re-enact the very terms of section 34(2)(b) by assuming legislative powers under the pretext of interpreting the scope of section 34(2) of the Act. There is no justification or warrant or necessity for this Court to embark upon such a course of action. The plea incidentally raised that the Joint Commissioner having once invoked the power under section 34 in respect of the order of the first appellate authority dated October 26, 1978, is not entitled to once again have recourse to section 34 to revise the very same order, though in respect of a different portion of the turnover considered by the first appellate authority, has no rhyme or reason to be sustained. In the earlier revision which culminated in the order dated January 25, 1982. The item of turnover that was sought to be dealt with and considered was totally different from the one considered in the subsequent revision culminating in the order dated July 11, 1983 and as a matter of fact the earlier order was not at all adverted to while passing the subsequent order. The subject-matter of the two revisions are admittedly distinct and separate and what is sought to be contended is that the appellate order being one and the same cannot be subjected to more than one revision under section 34 of the Act. The powers under section 34 is not only couched in wide terms but are specifically designed to safeguard the interests of revenue and the very object of the provision ought not to be whittled down on such technical considerations. That apart as per section 13 of the Tamil Nadu General Clauses Act, 1891, where an Act confers a power or imposes a duty then the power may be exercised and the duty shall be performed from time to time as occasion requires. So long as the order dated July 11, 1983, does not involve any review or modification of the earlier order dated January 25, 1982 and operate in different areas and relate to distinct and separate matters of consideration, there can be no disability whatsoever disentitling the Joint Commissioner in invoking the suo motu powers of revision more than once to bring to tax different aspects or item of turnover. The first point of challenge in T.C. No. 25 of 1984 consequently fails and shall stand rejected. As for the second ground of attack in T.C. No. 25 of 1984 is concerned, we are of the view that it is well founded. The assessing officer came to the conclusion from the return of some of the letters sent by the department to the agriculturists-purchasers that the sales claimed to have been made to agriculturists must have been merely manipulation of records to avail the benefit of exemption. The assessing officer came to the conclusion from the return of some of the letters sent by the department to the agriculturists-purchasers that the sales claimed to have been made to agriculturists must have been merely manipulation of records to avail the benefit of exemption. The first appellate authority carefully considered the records and the nature of the entries in the bills and the explanation of the appellants and held that so far as all the sales have been fully supported by bills and the sale bills also show that the buyers are only agriculturists as seen from the addresses noted in the sale bills, merely because the postal authorities returned the communication, in some of the cases, for want of sufficient address alone, it cannot be held that the appellants clandestinely crushed the kernels and sold oil and oil cake. This finding came to be validly recorded by the competent appellate authority on an appreciation of the materials and facts placed before it. The conclusion arrived at by the said appellate authority, in our view, could not be said to be without any basis or vitiated by any patent error of law or perversity of approach. While that be the position, could the Joint Commissioner choose to disturb those findings merely because he thinks he is superior in the hierarchy of the department and simply because in his view the appellate authority was wrong and the assessing officer alone was right. This Court on more than one occasion has discountenanced such moves on the part of the revisional authority exercising suo motu powers in a casual or routine manner as a matter of course. The return of some of the letters with an endorsement that the addressees were not available do not per se necessarily prove that no such persons existed or that such persons were merely fictitious. The reliance placed upon section 10 of the Act is also inappropriate. It is only when taxable transaction was said to have occurred or happened the burden becomes that of the assessee to show that such transactions are not taxable in their hands. The reasoning of the Joint Commissioner in para 10 of his order under challenge only smacks of predetermination and does not indicate any judicious consideration of the legality or propriety of the findings rendered by the Appellate Assistant Commissioner. The reasoning of the Joint Commissioner in para 10 of his order under challenge only smacks of predetermination and does not indicate any judicious consideration of the legality or propriety of the findings rendered by the Appellate Assistant Commissioner. Therefore, we are of the view that the resort to the suo motu powers of revision in this case, made by the Joint Commissioner could not be justified in law and the order of the Joint Commissioner dated July 11, 1983, shall stand hereby set aside and the turnover covered by the same shall stand deleted and excluded from the taxable turnover of the assessee as held by the first appellate authority. So far as T.C. No. 77 of 1984 is concerned, the learned counsel for the appellants placed heavy reliance on the decision of a Division Bench of this Court in Reliance Motor Company Private Ltd. v. State of Tamil Nadu [1992] 84 STC 201 to contend that the Joint Commissioner had no jurisdiction under section 34 to bring to tax for the first time turnover which has allegedly escaped assessment when it was neither the subject-matter of assessment proceedings nor appellate proceedings and that even if he is considered to have such a power it should conform to the period of limitation prescribed in section 16(1) of the Act. We are of the view that the decision in that case should be considered as having been rendered in the peculiar circumstances of that case and not as laying down any principle of general application and at any rate to a case like the one before us. As could be seen from para 3 of the decision reported in [1992] 84 STC 201 (Mad.) (Reliance Motor Company Private Ltd. v. State of Tamil Nadu), the assessee in that case appears to have been assessed by the assessing officer by an order dated October 30, 1976. An appeal filed as against a part of the turnover before the first appellate authority was allowed by the said authority on October 6, 1978 and the total and taxable turnover for the year was redetermined as per the order of the appellate authority. An appeal filed as against a part of the turnover before the first appellate authority was allowed by the said authority on October 6, 1978 and the total and taxable turnover for the year was redetermined as per the order of the appellate authority. At that stage or thereafter there appears to have been an inspection of the business premises of the assessee on July 17, 1980 and details regarding certain suppressions came to light for the first time and such materials were sought to be utilised to bring to assessment the turnover which was unearthed as a result of the inspection in the year 1980 by invoking the revisional powers of section 34 of the Act. The Division Bench sustained the objection of the assessee that the Joint Commissioner exceeded his powers while exercising jurisdiction under section 34 of the Act to bring to tax the alleged escaped turnover for the first time when it was neither the subject-matter of assessment proceedings nor appellate proceedings. The Division Bench also relied upon the earlier decision in A. Velayutha Raja v. Board of Revenue (C.T.), Madras [1970] 26 STC 176 (Mad.) to sustain also the plea of limitation that when what really the Joint Commissioner purported to do was to bring to tax the alleged escaped turnover to account for the first time he could not have done it beyond the period of limitation prescribed under section 16(1) of the Act providing for assessment of escaped turnover or liability. There is no comparison of the said case to the one under consideration by us now and the case on hand could not be considered as one falling within the category of cases visualised under section 16(1) of the Act, but in our view squarely falls within the scope of revisional powers as would be pointed out in our consideration to follow, hereinafter. The decision in A. Velayutha Raja v. Board of Revenue (C.T.), Madras 5 [1970] 26 STC 176 (Mad.) was often found to be pressed into service by assessees to their advantage, out of context. The decision in A. Velayutha Raja v. Board of Revenue (C.T.), Madras 5 [1970] 26 STC 176 (Mad.) was often found to be pressed into service by assessees to their advantage, out of context. Another Division Bench of this Court, presided over by the very learned Chief Justice who presided over the Division Bench which rendered the decision reported in [1992] 84 STC 201 (Mad.) (Reliance Motor Company Private Ltd. v. State of Tamil Nadu) to which one of us (Raju, J.) was a party had an occasion to deal with the ratio of the above decision and the relevant scope inter se of section 16(1) and section 34 and declared the position of law, in the decision reported in S.M.K. Sons v. State of Tamil Nadu [1992] 84 STC 18 (Mad.); (1992) 1 MTCR 67 in the following terms : "Likewise, the decision in Velayutha Raja v. Board of Revenue (C.T.) [1970] 26 STC 176 (Mad.) seems to have been rendered in the context of the exercise of suo motu powers of revision alone of the Board of Revenue and that too without reference to an earlier decision of a co-ordinate Bench of this Court to which one of the learned Judges (Ramaprasada Rao, J.) was also a party and to which a reference will be made hereinafter. The view expressed in the said decision that the provision as to the period of limitation within which escaped turnover can be brought to tax as provided in section 16(1) of the Act equally applies when such an order is sought to be passed by the Board in exercise of its powers under section 34 of the Act, in our view, needs to be confined to the peculiar facts and circumstances of the case and not as an invariable proposition of law of general application for the simple reason that such a construction would be diametrically opposed to the scheme of the provisions of the Act, the distinct and separate nature, character and scope of powers of the various authorities as well as their object. It is one thing to state that a particular power is vested only with a particular authority specified under the Act with certain limitations but another thing to read into the exercise of a statutory power conferred upon the competent authority limitations from outside and de hors the very provisions themselves. It is one thing to state that a particular power is vested only with a particular authority specified under the Act with certain limitations but another thing to read into the exercise of a statutory power conferred upon the competent authority limitations from outside and de hors the very provisions themselves. So long as the scope of a particular power conferred upon a specified authority under a particular provision of the Act permits that authority to do a particular thing, limitations aliunde cannot be imported on such exercise of its powers. Adopting such a course would amount to the courts themselves legislating and not confining themselves to their accredited task of interpreting and laying down the law. As a matter of fact, in our view, even the decisions relied upon in the said judgment do not warrant such an extreme proposition of law." It is by now well-settled by the authoritative pronouncement of the apex Court in Prakash Amichand Shah v. State of Gujarat AIR 1986 SC 468 while dealing with the binding nature of the precedent of the judgments, the correct position of law to be thus : "A decision ordinarily is a decision on the case before the court while the principle underlying the decision would be binding as a precedent in a case which comes up for decision subsequently. Hence while applying the decision to a later case, the court which is dealing with it should carefully try to ascertain the true principle laid down by the previous decision. A decision often takes its colour from the questions involved in the case in which it is rendered. The scope and authority of a precedent should never be expanded unnecessarily beyond the needs of a given situation." Thus considered, it could be seen that the decision reported in [1992] 84 STC 201 (Mad.) (Reliance Motor Company Private Ltd. v. State of Tamil Nadu) relied upon for the appellants could not be held applicable to the case before us. As could be seen from the relevant orders of the assessing officers and the first appellate authority in the case before us, the assessing officer estimated, on the basis of the materials unearthed and slips recovered the turnover in respect of actual suppression of first purchases of groundnut kernel, locally made, at Rs. 2,55,107 and suppressions to the tune of Rs. 25,510.70. 2,55,107 and suppressions to the tune of Rs. 25,510.70. When the appellants challenged the same in appeal before the Appellate Assistant Commissioner, the said authority while confirming the suppressions only reduced the quantum as against the said category of turnover to Rs. 1,17,993.10. This was really the actuals of the suppressions as borne out by the slips recovered and in sustaining the levy to that extent the appellate authority also relied upon the admissions made by the appellants before the inspecting officers that the transactions noted in the amanat slips recovered related to purchase of groundnut from the villagers and the slips gave all the relevant details of individual purchases made on different occasions. Therefore, it cannot be said that this turnover was not the subject-matter of the order of assessment or that of the appellate authority. Since the authorities below did not pursue the matter further and abruptly abandoned their duties and obligations to enquire into and consider the manner and method of the disposal of the stock so held to have been acquired, the Joint Commissioner considered that the orders of the authorities below suffered an error to that extent inasmuch as the assessees failed to disclose or prove that they have sold the said stock only as kernels in their turn, and therefore taking into account their normal business activities as dealers in oil and oil cakes legitimately came to the conclusion that the assessees should in the normal course of business, ought to have converted the stock into oil and oil cake and sold them, as such. This is only a legal inference to be drawn on the materials already available on record. The correctness or otherwise of the conclusions so drawn would be separately considered hereinafter but it could not be said at any rate in this case that the subject-matter of revisions by the Joint Commissioner was something outside the materials available on record of the assessing and appellate authorities or a material secured for the first time after the assessment and appeal came to be concluded. The Joint Commissioner, therefore, only revised the orders of the authorities below and set right the blunder and mistake committed in the form of glaring omission by the authorities in the discharge of their duties and such a course of action in our view is strictly within the scope of suo motu revisional powers, simpliciter, and this action of the Joint Commissioner does not partake the character of an escaped assessment within the meaning of scope of section 16(1) of the Act. This Court as well as the apex Court has held that it would be incorrect to generally contend that the exercise of power by the revisional authority must in all cases be confined and restricted to the records maintained by the subordinate authorities below. In Kutty Flush Doors and Furniture Co. (P.) Ltd. v. State of Tamil Nadu [1984] 57 STC 74, a Division Bench of this Court held while considering the scope of section 32, a similar provision like section 34, that the Legislature does not impose any such condition and the revisional authority is not prevented from perusing the information about the omission of a taxable turnover from assessment, from material available even outside the record of assessment. The case before us, as we have referred to earlier is not even of one such a case. In Venkateswara Metal Industries v. State of Tamil Nadu [1989] 74 STC 364, another Division Bench of this Court held as hereunder : "The revisional order passed by the Board of Revenue is within a period prescribed by that section. Therefore, the power of limitation prescribed under section 16 of the Act will not apply to the revision in the instant case. Further in the decision reported in Padmavathi v. State of Tamil Nadu [1979] 44 STC 446 (Mad.) while considering the scope of sections 16 and 32 (the revision by the Deputy Commissioner is analogous to section 34) it is held as follows : '..... the two sections are mutually exclusive and give different powers to different authorities. Therefore, if action could be taken under one section, it does not follow that action could not be taken under the other. Where it is possible to act under two provisions, the department may resort to the one instead of the other and it cannot be compelled to proceed under only one of the two provisions. Therefore, if action could be taken under one section, it does not follow that action could not be taken under the other. Where it is possible to act under two provisions, the department may resort to the one instead of the other and it cannot be compelled to proceed under only one of the two provisions. Section 32 provides for the examination of the order passed by a subordinate authority under certain provisions set out therein. So long as the jurisdiction is exercised with respect to an order contemplated by the section, there would be no error in the exercise of jurisdiction.' The Division Bench also held on the relative scope of sections 16 and 34 in the following terms : On a consideration of the above decisions, we are of the view that sections 16 and 34 of the Tamil Nadu General Sales Tax Act are independent and the limitation prescribed under section 16 will not be applicable to a revision under section 34 of the Act and in any event, in this case, since the original assessment was not revised under section 16 the limitation prescribed under section 16 will not be applicable to a revision under section 34. Further we are of the view that section 34 gives wide power to reassess the turnover as in the case of the original assessing authority." The exercise of powers, so far as the present case before us is concerned, is one in our view, squarely coming within the four corners of suo motu revisional powers conferred upon the Joint Commissioner under section 34 of the Act and consequently there is no merit whatsoever in the plea made on behalf of the appellants that it has also to satisfy the period of limitation as prescribed under section 16(1) of the Act. The provisions of section 34 of the Act contain their own period of limitation and the exercise of power by the Joint Commissioner is well within the said period of limitation. Consequently we reject the said plea made on behalf of the appellants in T.C. No. 77 of 1984. The other contention made on behalf of the appellants is that on merits, there was no basis or material at all to justify the revision and subject to the levy of tax, the turnover worked out as relatable to the sales of groundnut oil and oil cake. The other contention made on behalf of the appellants is that on merits, there was no basis or material at all to justify the revision and subject to the levy of tax, the turnover worked out as relatable to the sales of groundnut oil and oil cake. We have carefully gone through the order of the Joint Commissioner. The finding of the appellate authority itself that the appellants have suppressed the purchase turnover of groundnut kernel locally acquired from agriculturists to the tune of Rs. 1,17,993.10 has become final and admittedly has not been challenged further by way of any appeal to the Tribunal. If that be the position, as we have referred to supra, the appellants are obliged to produce sufficient materials before the authorities as to how they came to dispose of the stock of groundnut kernel locally acquired by first purchase from the agriculturists by the assessees. In the absence of any proof whatsoever that they in their turn sold the said stock only as groundnut kernel we see nothing wrong in the Joint Commissioner presuming, having regard to the normal business activities of the appellants, as dealers in oil and oil cake, that the appellants would have in the normal course of their business converted the groundnut kernel of the value of Rs. 1,17,993.10 into oil and groundnut cake and would have sold them. The general plea that they do not have their own oil mill for crushing the groundnut kernel has no meaning or sense in the light of the indisputable position that they are dealers in groundnut oil and oil cake and they could reasonably be presumed to have crushed the groundnut kernel into oil and oil cake and sold the same particularly when it is not necessary that they should have their own mill to crush the groundnut kernel into oil or oil cake. The presumption drawn by the Joint Commissioner in exercise of his suo motu powers, could not, on the peculiar facts and circumstances of the case, as reflected from the materials available in T.C. No. 77 of 1984 be said to be either patently illegal or palpably wrong or demonstrably perverse so as to call for the interference of this Court in these appeals. The learned counsel for the appellants also placed reliance in this regard on the unreported decision of this Court in State of Tamil Nadu v. Kaveri Oil Seeds Processing Co., Theni (T.C. No. 1424 of 1980 dated March 17, 1981). That was a case where this Court confirmed the factual findings arrived at by the Appellate Tribunal, the Tribunal being a final authority on facts, and in our view, the said judgment cannot in any manner come to the assistance of the appellants in this case. We are, therefore, of the view that the conclusions arrived at by the Joint Commissioner in the present case are just and reasonable and that no exception could be taken to the findings recorded by the Joint Commissioner. For all the reasons stated above, we see no reason to sustain the challenge to the order of the Joint Commissioner made on January 25, 1982, which is the subject-matter of challenge in T.C. No. 77 of 1984. For all the reasons stated above, T.C. No. 25 of 1984 shall stand allowed and T.C. No. 77 of 1984 shall stand dismissed, but in the circumstances of the case, there will be no order as to costs. T.C. No. 25 of 1984 allowed. T.C. No. 77 of 1984 dismissed.