S. B. MAJMUDAR, CJ. ( 1 ) IN these Appeals a common Order passed by the learned Single judge on 16th June, 1994 in Writ Petitions No. 10924 to 10930 of 1994 amongst others has been brought in challenge. These Writ petitioners are having Flour Mills in the State. Their contention is that under Section 6b of the Karnataka Sales Tax Act, 1957 (hereinafter referred to as the 'act'), the total turnover of every dealer is liable to turnover Tax but the Proviso to the said Section, however excludes the turnover relating to several transactions listed therein, from turnover tax. Item (ii) under the Proviso excludes the turnover relating to sale or purchase of goods specified in the Fourth Schedule to the act. Wheat is one of the items listed in the Fourth Schedule to the Act and therefore the turnover relating to wheat is exempted from turnover Tax. The respondent-revenue authorities considered 'wheat products' as different from 'wheat' and therefore the exemption which was available in respect of wheat listed in Fourth Schedule was not extended to wheat products like - soji, maida and atta etc. , and according to the revenue authorities the turnovers of the appellants dealing with these wheat products were liable to be subjected to turnover Tax under Section 6b, as they did not fall within the exempted items. Earlier the appellants could convince the assessing authorities on the basis of the Division Bench Decision of this Court in new SWASTIC FLOUR MILLS vs STATE OF KARNATAKA that wheat and wheat products are the same for the purpose of the aforesaid Proviso. However, that Decision of this High Court got reversed by the Supreme Court in the case in RAJASTHAN ROLLER flour MILLS ASSOCIATION vs STATE OF RAJASTHAN. In view of the Supreme Court Decision it became clear that wheat and wheat products had to be treated as different items and therefore, wheat products would not get the benefit of exemption from the payment of turnover tax under Section 6b of the Act. Taking a clue from this decision, revisional proceedings were initiated against the assessment orders by the authorities acting under Section 21, sub-section (2) of the Act and the revisional proceedings, following the Decision of the Supreme Court, resulted in orders against the appellants. That is how the appellants landed in this Court by way of the aforesaid Writ Petitions. Taking a clue from this decision, revisional proceedings were initiated against the assessment orders by the authorities acting under Section 21, sub-section (2) of the Act and the revisional proceedings, following the Decision of the Supreme Court, resulted in orders against the appellants. That is how the appellants landed in this Court by way of the aforesaid Writ Petitions. These Petitions along with cher Writ petitions were heard by the learned Single Judge and by his common order confirmed the orders passed by the revisional authority. ( 2 ) 3 contentions were urged by the learned Counsel for the appellants before us in support of these Appeals - (1) The Decision of the Supreme Court in 91 STC 408 supra, cannot have any retrospective effect and cannot affect the past transactions. Therefore, the revisional authority could not have revised the assessment orders passed at a time when the earlier view of the karnataka High Court was holding the field and that the law declared by the Supreme Court can be treated to be prospective and applicable to only future transactions which would result in future assessment orders; (2) Even apart from the Supreme Court Decision already a Circular was issued by the Commissioner of Commercial taxes in exercise of powers under Section 3a of the Act, calling upon all the Assessing Authorities to follow the Decision of the Karnataka high Court as then existing and it treated wheat products and wheat as the same commodity and that Circular was not withdrawn at any time by the Commissioner, therefore, it remains binding on the assessing authorities. Accordingly, the revisional authorities could not have revised the earlier assessments relying on the later Decision of the Supreme Court; (3) In any case under Section 21, sub-section (2) of the Act, the Joint Commissioner had no jurisdiction to revise the orders of the then Assistant Commissioner, who had passed an order on 7. 10. 92, but who subsequently on legislative amendment became a Deputy Commissioner, with effect from 9. 11. 92. ( 3 ) IN our view there is no substance in any of these contentions. The reasons are obvious. 10. 92, but who subsequently on legislative amendment became a Deputy Commissioner, with effect from 9. 11. 92. ( 3 ) IN our view there is no substance in any of these contentions. The reasons are obvious. So far as the first contention is concerned, once the Supreme Court declared the law under Article 141 of the constitution by reversing the view of this Court and held that for purposes of Section 6b of the Karnataka Sales Tax Act, wheat and wheat products are different commodities and wheat products like soji, Maida and Atta were liable to Turnover Tax under the provisions of Section 6b, that Decision was binding on all the Authorities in the state and the Supreme Court Judgment had to be followed as law declared by the Supreme Court and had to be applied in all pending proceedings, at whatever stage they may be, whether before the assessing Authority or Appellate Authority or Revisional Authority. The Revisional Authority cannot say that it will not follow the Supreme court Decision, but it will follow the Karnataka High Court Decision, which was reversed and which was no longer a good law. It is of course true that the Supreme Court while laying down law under article 141 and in exercise of its paramount power can state that its decision or the declaration of law will apply to only future transactions and not to past transactions as was done in GOLAKNATH vs punjab. However, that power is not vested to any other Courts including High Court, much less in the assessing authorities under the act. We can in this connection usefully refer to a Decision of the supreme Court in the case of MAJ. GENL. A. S. GAURAYA vs thakur. The following pertinent observations made by the supreme Court in this connection may be referred to. "where the Sessions Court allowed a revision before it by bypassing the decision of Supreme Court on the point involved with the observation that a pronouncement as to the position of law in a judicial decision by the Supreme Court cannot be treated as a sort of legislation by the Parliament giving retrospective effect as to enjoin re-opening of all matters which have already become final and closed, the order of Sessions Court was held unjustified. There is nothing like any prospective operation alone of the law laid down by Supreme Court. There is nothing like any prospective operation alone of the law laid down by Supreme Court. The law laid down by that Court applies to all pending proceedings. If there would have been an earlier order of the High Court binding on Sessions judge it would have been a different matter. He got rid of the effect of Supreme Court's judgment by observing that a decision by that Court cannot be treated as "a sort of legislation by parliament" and thus overlooked the binding nature of the law declared by Supreme Court, mandating under Article 141, every court subordinate to that Court to accept it. "it must therefore, be held that the Decision of the Supreme Court in 91 STC 408 is binding on all Authorities in the Karnataka State exercising jurisdiction under Sales Tax Act and also binding on this court. First contention therefore, has to be rejected. So far as the second contention is concerned it may be that the commissioner might have issued a Circular on 25th August, 1991 bringing to the notice of all the assessing authorities under the Act to follow the Karnataka High Court Decision which was then holding the field. But once that Decision is no longer good law and reversed by the Supreme Court by 91 STC 408 (supra) that Circular lost all its efficacy. This is not a case in which the Commissioner of Commercial taxes had issued a Circular giving some more concession to the flour Millers for the purpose of exemption under Section 6b of the act, despite the settled legal position. This is a case in which the circular was issued merely on the basis of the Karnataka High Court judgment directing assessing authority to pass appropriate orders keeping in view the ratio of the Decision. Once the very basis of the circular is knocked out by the reversing Judgment of the Supreme court that Circular automatically became otiose. Even that apart the circular issued by the Commissioner under the Sales Tax Act cannot bind Judicial or quasi-judicial Authorities, as even the Proviso to section 3a makes it clear that no such orders, instructions and directions shall be issued so as to interfere with the discretion of any appellate Authority in the exercise of its appellate functions. Even that apart the circular issued by the Commissioner under the Sales Tax Act cannot bind Judicial or quasi-judicial Authorities, as even the Proviso to section 3a makes it clear that no such orders, instructions and directions shall be issued so as to interfere with the discretion of any appellate Authority in the exercise of its appellate functions. ( 4 ) EVEN that apart the Supreme Court in the case of BENGAL IRON CORPORATION AND ANOTHER vs COMMERCIAL TAX officer AND OTHERS, has clearly taken the view that such circulars issued by the authorities under the Sales Tax Act are not binding upon the quasi-judicial and Judicial Authorities functioning under the Act. Learned Counsel for the appellants in this connection submitted that Proviso to Section 3a (1) only states that such Circulars may not interfere with the Judicial discretion of the Appellate authority, but this is a case of revisional authority. Now it is too late in the day to contend as aforesaid, for the simple reason that revisional jurisdiction forms part of appellate jurisdiction as laid down by the supreme Court in SHANKAR RAMCHANDRA ABHYANKAR vs krishnaji DATTATRAYA BAPAT. Therefore, the second contention also has no force and it has to be rejected. ( 5 ) SO far as the last contention is concerned a mere look at Section 21 (2) of the Act makes it clear that there is no force in this contention. Section 21 sub-section (2) states the Joint Commissioner may on his own motion call for and examine the record of any order passed or proceedings recorded under the provisions of the Act, by an Assistant Commissioner or other Officer subordinate to him for the purpose of satisfying himself as to the legality or propriety of such order or as to the regularity of such proceedings, in so far as it is prejudicial to the interests of the revenue and may pass such order with respect thereto as he thinks fit. ( 6 ) IT cannot be disputed and it is not disputed that the impugned order is passed on 22nd February, 1994 by the Joint Commissioner of commercial Taxes and he has revised the order passed by the assistant Commissioner on 7. 10. 1992. It also cannot be disputed that the Assistant Commissioner as on the date when the revisional order is passed, was subordinate to the Joint Commissioner. 10. 1992. It also cannot be disputed that the Assistant Commissioner as on the date when the revisional order is passed, was subordinate to the Joint Commissioner. But the submission of the learned Counsel is that Assistant Commissioner who passed the earlier order on 7. 10. 1992, which was sought to be revised subsequently under Section 21 (2) of the Act by the Joint commissioner, was at that time acting as Assistant Commissioner but subsequently became Deputy Commissioner. If it is so, this order can be treated to be of Deputy Commissioner which could not be revised by the Joint Commissioner. It is difficult to agree. The order of assistant Commissioner, passed on 7. 10. 92, remains the order of the assistant Commissioner and not of Deputy Commissioner as on that date. Even if subsequently Assistant Commissioner became Deputy commissioner, the earlier order passed by him cannot partake the character of an order passed by the Deputy Commissioner. It is only if after he became Deputy Commissioner he had passed an order, that would partake the character of an order of Deputy Commissioner. If this is not so, an order passed by a District Judge, later elevated to the High Court Bench, has to be termed as order passed by a High court Judge, which cannot be revised by the High Court. Therefore, on the facts of the case it must be held that it was the Assistant commissioner's order, passed on 7. 10. 92, which was sought to be revised by the Joint Commissioner on 22nd February, 1994 and such an exercise was clearly permissible and was within the four corners of section 21 (2) of the Act. The last contention is also therefore devoid of any substance. It is therefore, rejected. These were the only contentions canvassed in support of the Appeals and as they fail the appeals fail and therefore, dismissed. --- *** --- .