MAJMUDAR, J. ( 1 ) THESE three Appeals under Section 16 of Karnataka Tax on Entry of Goods Act, 1979 (hereinafter referred to as "the Act") are taken out by an assessee M/s. Steel Suppliers, being aggrieved by identical orders dated 22. 7. 1993, passed by the Joint Commissioner of commercial Taxes (Administration), Bangalore Sub-Division, bangalore in No. SMR. KTEG. 187/89-90, SMR. KTEG. 188/89-90 and smr. KTEG. 189/89-90. All these three orders are passed under section 15 (1) of the Act, though wrongly mentioned as orders under section 16 (1) of the Act. T. A. (ET) 10/94 is concerned with period of assessment from 16. 11. 1982 to 3. 11. 1983, TA (ET)11/94 concerns the period of assessment from 1. 4. 1982 to 15. 11. 1982 and TA (ET) 12/94 concerns period of assessment from 4. 11. 1983 to 23. 10. 1984. By the orders under appeal, assessment orders passed by the Assistant commissioner of Commercial Taxes, 26th Circle, Bangalore in the case of the appellant for the concerned periods have been revised by the revisional authority and the assessing authority is directed to issue demand notice accordingly. ( 2 ) A few relevant facts leading to these Appeals are required to be noted at the outset. The appellant is dealing in Iron and Steel and is registered under the Act, on the file of the Assistant Commissioner of Commercial taxes, 26th Circle, Bangalore. For the assessment period 16. 11. 1982 to 3. 11. 1983 assessment was completed by the Assistant commissioner by his order dated 4. 8. 1986. The said authority also completed the assessment on the same day for the assessment period 1. 4. 1982 to 15. 11. 1982 and similarly on the same day he also completed the assessment for the period 4. 11. 1983 to 23. 10. 1984. ( 3 ) THE Deputy Commissioner of Commercial Taxes (Administration), City Division-l took up the assessment records of the appellant and suo motu initiated revisionai proceedings as provided by Section 15 (1) of the Act and issued show-cause notices dated 22. 7. 1989 on the ground that the orders of the Assessing Authorities were erroneous and prejudicial to the interest of the Revenue. 7. 1989 on the ground that the orders of the Assessing Authorities were erroneous and prejudicial to the interest of the Revenue. The basis of the show-cause notices was that in the concerned assessment years, the appellant had purchased Iron and Steel from m/s Tata Iron and Steel Company and others and brought the purchased goods within the local area and therefore, these purchased materials had entered the local limits of Bangalore, on which the appellant assessee was liable to pay the Entry Tax and still the assessing authority had treated these purchases as local purchases and had exempted them from the payment of Entry Tax These orders of the assessing authority, according to the revisional authority, were erroneous in so far as they were prejudicial to the interest of the revenue and consequently, notices were issued to the assessee to show-cause why orders of the assessing authority should not be revised. ( 4 ) THE appellant filed its replies dated 31. 7. 1989 through his chartered Accountant, to the show-cause notices dated 22. 7. 1989. In the said reply, two months time was sought for supplying Form No. 30 for establishing its case that the purchases in question were local purchases from the sellers who had imported those goods and therefore, liability to pay Entry Tax was of the sellers and not of the appellant. It appears that thereafter the matters were adjourned by the revisional authority, but the Form No. 30 were not produced. Under these circumstances, second show-cause notice was issued on 11. 3. 1992. Reply was filed on 11. 5. 1992 by the appellant. In the said reply, the appellant took-up the contention that though he had purchased the goods from outside the local limits of Bangalore City corporation from the godowns of the sellers situated outside the municipal limits, he had taken those goods to his own godowns which were also situated outside the Municipal Limits and from there appellant effected the sales to the purchasers. Thus a new case was put forward by the appellant in the second reply dated 14-5-1992 that though the goods were purchased by the appellant himself from local sellers, but he purchased them outside the Municipal Limits and had disposed them of also outside the Municipal limits. Meaning thereby he had not caused the entry of the goods in Bangalore Municipal limits. Meaning thereby he had not caused the entry of the goods in Bangalore Municipal limits. Thereafter, the third show-cause notice was issued to the appellant on 14-7-1993 which was replied on 21-7-1993 by submitting that sufficient correspondence has been entered into and the appellant has already submitted by his earlier reply what he has to say. It is, thereafter that the impugned orders came to be passed by the revisional authority on 22-7-1993. As noted earlier, the dissatisfied assessee is in appeal against that revisional orders under Section 16 (1) of the Act. ( 5 ) WE have heard Sri Kamath, learned Counse! for the appellant and Sri Ramesh, learned Standing Counsel for the Department, respondent. As common question of fact and law arises in these appeals, all these Appeals were heard together by consent of learned counsel for the parties and are being disposed of by this common judgment. ( 6 ) SRI Kamath, learned Counsel for the appellant, raised the following contentions in support of the Appeals:1. The Joint Commissioner of Commercial Taxes (Administration) bangalore who has passed the impugned order on 22-7-1993 in these three Cases has no jurisdiction to exercise powers under Section 15 (1) and therefore, the orders are null and void. In the alternative and on merits, it was submitted. 2. That the Revisional authority has patently erred in law in holding that the assessment orders were erroneous and prejudicial to the interest of the revenue though on correct appreciation ot facts on record, it ought to have been held that assessment orders were perfectly justified and legal and required no interference by the Revisional authority. We shall deal with these contentions seriatim. Point No. 1: So far as the question of the jurisdiction of the Authority passing the impugned order is concerned, the learned Counsel for the appellants submitted that the show cause notices were issued, by the deputy Commissioner. The impugned order is passed by Joint commissioner of Commercial Taxes. Therefore, the Notification dated 31-7-1981 issued by the Commissioner of Commercial Taxes in exercise of his powers under Section 15 (1) empowering Deputy commissioner of Commercial Taxes (Admn.) to exercise the powers conferred by sub-section (1) of Section 15 could not authorise the joint Commissioner to pass such an order. Therefore, the Notification dated 31-7-1981 issued by the Commissioner of Commercial Taxes in exercise of his powers under Section 15 (1) empowering Deputy commissioner of Commercial Taxes (Admn.) to exercise the powers conferred by sub-section (1) of Section 15 could not authorise the joint Commissioner to pass such an order. It was also submitted that the Notification dated 31-7-1981 was outside the scope of Section 15 (1) of the Act as it did not involve any special empowerment to the concerned officer, but it was merely a general empowerment. ( 7 ) IT was next submitted by Sri Kamath, learned Counsel for appellants that a later Notification dated 19-1-93/22-4-93 was issued by State of Karnataka in exercise of its powers under Section 12 (1) of the Act empowering specified officers as mentioned in Column 2 of the Table as found in the said Notification to exercise power under section 15 of the said Act in respect of the dealers falling in the areas specified in Column-4 of the Table. The Joint Commissioner of commercial Taxes (Admn.) in any case lost his jurisdiction to pass the impugned order after the coming into operation of the aforesaid notification as the order is passed on 22-7-93 three months after the gazetting of the aforesaid Notification. As per the said Notification all pending proceedings initiated by the authorities under Section 15 other than Commissioner of Commercial Taxes had stood transferred to the respective Zonal Additional Commissioners of Commercial taxes in so far as dealers coming under their respective jurisdiction were concerned. That so far as the appellant is concerned he was a dealer within the jurisdiction corresponding to that of the Joint commissioner of Commercial Taxes (Admn.) of City Division-1 of bangalore and hence as per serial No. 1 of the Table found in the said notification with effect from 22-4-83 only Addl. Commissioner of commercial Taxes, City Zone-1 could proceed with the said proceedings under Section 15 (1) of the Act. Consequently, the Joint commissioner of Commercial Taxes (Admn.) City Division-1 was not competent to pass the impugned order even on this score. ( 8 ) ON the other hand Sri Ramesh, learned standing Counsel for the Respondent-Revenue Authority submitted that the impugned order passed by the Joint Commissioner is perfectly within his jurisdiction. In this connection Mr. Consequently, the Joint commissioner of Commercial Taxes (Admn.) City Division-1 was not competent to pass the impugned order even on this score. ( 8 ) ON the other hand Sri Ramesh, learned standing Counsel for the Respondent-Revenue Authority submitted that the impugned order passed by the Joint Commissioner is perfectly within his jurisdiction. In this connection Mr. Ramesh firstly submitted that under section 15 (1) the Legislature has in terms authorised the commissioner to specially empower any other officer to exercise powers under Section 15 (1), that such empowered officer would function on his own and independently of the officers expressly mentioned by the Legislature in earlier part of Section 15 Who on account of Legislative empowerment can of their own exercise such powers. That by virtue of Notification dated 31-7-81 the then commissioner of Commercial Taxes, Karnataka, Bangalore, in exercise of his powers under Section 15 (1) 3rd part, had specially empowered the Deputy Commissioner of Commercial Taxes (Admn.) to exercise powers under Section 15 (1) in regard to any orders passed by any officers subordinate to him. That it is not in dispute that the original order passed by the Assistant Commissioner was by an officer subordinate to Deputy Commissioner and therefore the Deputy commissioner by virtue of the aforesaid delegation of powers by the commissioner could validly exercise jurisdiction under Section 15 (1), that accordingly the show-cause notices were issued by the Deputy commissioner. That the Notification dated 31-7-81 specially empowers the Deputy Commissioner of Commercial Taxes (Admn.) and does not involve any general empowerment as alleged by learned Counsel for the appellant. Mr. Ramesh further submitted that the said Notification has not been rescinded or superseded or modified by Commissioner at any time thereafter and it was in force when the impugned order came to be passed. ( 9 ) MR. RAMESH, further submitted that on 31-7-81 when the said Notification was issued by the Commissioner under Section 15 (1) it specially empowered the Deputy Commissioner of Commercial Taxes (Admn.) to exercise his aforesaid powers. The term 'deputy commissioner' was not defined by the Act but it got defined in 1985. Therefore, from 1985 onwards the said Notification had to be read in the light of the term 'deputy Commissioner' as defined by Section 2 (3) (a) as brought on the statute book with effect from 10-9-85 by the amending Act 28/1985. The term 'deputy commissioner' was not defined by the Act but it got defined in 1985. Therefore, from 1985 onwards the said Notification had to be read in the light of the term 'deputy Commissioner' as defined by Section 2 (3) (a) as brought on the statute book with effect from 10-9-85 by the amending Act 28/1985. He further submitted that because of the subsequent amendment in the Act brought about by Karnataka Act-5 of 1993, for expression Deputy Commissioner the term 'joint commissioner' stood substituted in the Act and that substituted nomenclature of 'joint Commissioner' for the erstwhile Deputy commissioner had to be read in the Notification of 1981 as ft was a statutory notification which had to be read with the Act and as apart of the Act. Mr. Ramesh, in this connection also heavily leaned on section 20 of the Karnataka General Clauses Act 1899. Mr. Ramesh, therefore, contends that on the date when the impugned order was passed the Notification dated 31 -7-81 would squarely apply to empower the Joint Commissioner of Commercial Taxes (Admn.) to pass such order as the earlier term 'the Deputy Commissioner of commercial Taxes (Admn.)' employed therein will have to be read as joint Commissioner of Commercial Taxes (Admn.), in the light of the amending Act 5/93 which had already come into effect from 4-2-93. ( 10 ) IN this connection Mr. Ramesh invited our attention to the Judgments of the Supreme Court to which we will make reference hereinafter. Referring to the Notification dated 19-1/27-4-1993 issued by the State of Karnataka under Section 12 (1), Mr. Ramesh submitted that the said Notification has no effect on the present proceedings as a (l that it tried to do was to bifurcate the jurisdiction of erstwhile additional Commissioner of Bangalore into jurisdictions of five additional Commissioners of five Divisions and reallocate all pending proceedings initiated under Section 15 (1) by Statutory Authorities other than the Commissioner under Section 15 (1) which would include Joint Commissioner or Additional Commissioner by virtue of their own powers under Section 15 (1) and not as delegate of the commissioner. Only these proceedings stood transferred to the additional Commissioners of respective Zones as indicated in the table to the Notification. That was the limited effect of Notification under Section 12 (1 ). Only these proceedings stood transferred to the additional Commissioners of respective Zones as indicated in the table to the Notification. That was the limited effect of Notification under Section 12 (1 ). In this connection he submitted that if the contention of the learned Counsel for the appellant is accepted, then it would amount to repealing of 3rd part of Section 15 and abolishing the clause earmarking the capacity of the delegate of the commissioner for exercise of powers under Section 15 (1) and that too by the Executive Authority like State Government which itself had a delegated Legislative function under Section 12 (1 ). That such a delegate could not repeal any provision of the statute enacted by the parent legislation itself. ( 11 ) IN the light of these rival contentions on the question of jurisdiction of the Joint Commissioner of Commercial Taxes (Admn.) who passed the impugned order, we now proceed to tackle this problem. In the first instant, we may refer to Section 15 of the Act as it stood at the time when the showcause notices were issued against the appellant. Section 15 (1) which is the only material provision for our present purpose read as under at the time first show-cause notice dated 22-7-1989 was issued:"15. (1 ). Revision by the Commissioner, of orders prejudicial to revenue:- the Commissioner or any other officer specially empowered by the Commissioner in this behalf may call for and examine the record of any proceedings under this Act, and if he considers that any order passed therein by any officer is erroneous in so far as it is prejudicial to the interest of revenue, he may, if necessary, stay the operation of such order for such period as he deems necessary and after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment. " ( 12 ) BY the time second show-cause notice dated 11-3-92 was issued, Section 15 (1) stood as under:"15. (1 ). " ( 12 ) BY the time second show-cause notice dated 11-3-92 was issued, Section 15 (1) stood as under:"15. (1 ). Revision by the Commissioner or the Joint Commissioner of orders prejudicial to revenue:- (1) The Commissioner or the joint Commissioner or any other officer specially empowered by the Commissioner in this behalf may call for and examine the record of any proceedings under this Act, and if he considers that any order passed therein by any officer is erroneous in so far as it is prejudicial to the interest of revenue, he may, if necessary, stay the operation of such order for such period as he deems necessary and after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment. " ( 13 ) BY the time the III show-cause notice dated 14-7-93 was issued and also by the time the impugned order was passed on 22-7-93, Section 15 (1) stood as under:"15. (1 ). Revision by the Commissioner or the Additional commissioner of orders prejudicial to revenue: (1) The Commissioner or the Additional Commissioner or any other officer specially empowered by the Commissioner in this behalf may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by any officer is erroneous in so far as it is prejudicial to the interests of the revenue, he may, if necessary, stay the operation of such order for such period as he deems necessary and after giving the assessee an opportunity being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment. " ( 14 ) IN these proceedings we are mainly concerned with the jurisdiction of the Authority passing the order dated 22-7-93. Therefore, Section 15 (1) as it stood then has to be kept in view. As per the said provision the Legislature has earmarked three authorities which can exercise powers under Section 15 (1) viz. , (1) commissioner himself (2 ). Therefore, Section 15 (1) as it stood then has to be kept in view. As per the said provision the Legislature has earmarked three authorities which can exercise powers under Section 15 (1) viz. , (1) commissioner himself (2 ). The Additional Commissioner or (3) Any other officer specially empowered by the Commissioner in this behalf. It is not the case of either side that the Commissioner or the Additional commissioner has passed the impugned order acting as earmarked statutory authority under Section 15 (1) by Legislature itself. In this connection both the sides have relied upon the Illrd part of Section 15 (1) viz. , special empowerment of any other officers by the commissioner to exercise such powers. Mr. Kamath for Appellant contends that Joint Commissioner of Commercial Taxes (Admn.) who passed the impugned order was not such a specially empowered officer by the Commissioner, so as to fit in with the description of such officer as found in the III part of Section earmarking such an authority for the purpose. While Revenue on the other hand contends that the joint Commissioner, Commercial Taxes (Admn.) was such a specially empowered officer by the Commissioner and therefore he could exercise such power as delegate of the Commissioner falling in the 3rd category of officers who could exercise such powers under section 15 (1 ). For resolving this controversy we will have to first turn to the parent Notification issued by the Commissioner of Commercial taxes under Section 15 (1) in 1981, ( 15 ) WE have already seen that under Section 15 (1) of the Act, the officer specially empowered by the Commissioner may also exercise powers of revision against the orders of his subordinates. In exercise of this power, the then Commissioner of Commercial Taxes, karnataka Sri I. N. Sing had issued Notification dated 31-7-1991 empowering and authorising the Deputy Commissioner of commercial Taxes (Administration) to exercise the powers conferred by sub-section (1) of Section 15 in regard to any orders passed by any subordinate officer, within their respective jurisdic onunder the karnataka Sales Tax Act, 1957. ( 16 ) THE first contention of Sri Kamath, learned Counsel for the appellant against the said Notification is that even if this Notification has continued to operate all throughout, it would not be effective and valid inasmuch as Section 15 (1) of the Act under which it is issued, requires the Commissioner to specially empower the concerned officer mentioned in the Notification. That the Notification on the other hand, authorises the Deputy Commissioners of Commercial Taxes (Administration) in general and they are empowered to exercise revisional powers under sub-section (1) of Section 15 in regard to any order passed by any officer subordinate to them within their respective jurisdiction under the Karnataka Saies Tax Act. Thus this notification empowers all such Deputy Commissioners working in any part of the Karnataka State, while the Notification issued under section 15 (1) requires special empowerment to a particular named officer enabling him to exercise revisional powers qua subordinates working under him in the given jurisdiction. As that is not done, the notification is inoperative and cannot be treated to be making special empowerment to the then Deputy Commissioner of Commercial taxes (Administration) Bangalore to deal with the petitioner's case. This contention is tried to be met by Sri Ramesh, for the Revenue on two grounds. Firstly, he submits that validity of such Notification cannot be challenged in appeal in hierarchy of proceedings under the act. For that purpose, he relies upon the Decision of the Allahabad high Court in 24 STC 74. In our view, it is not necessary to consider the applicability of that Decision as Mr. Karnath, for the appellant made it clear that he is not submitting that the said Notification is ultra vires Section 15 (1) of the Act, but his submission is limited to. the effect that the said Notification will not amount to conferring any special empowerment under Section 15 (1) to the then Deputy commissioner of Commercial Taxes (Administration) Bangalore. We have, however, to consider whether the said Notification confers general empowerment to such officers or confers special empowerment to the concerned officers for exercising, revisional powers over the orders of the subordinates within their respective jurisdiction. So far as this aspect of the matter is concerned, there is a direct Decision of the Supreme Court on the point which clinches the issue. So far as this aspect of the matter is concerned, there is a direct Decision of the Supreme Court on the point which clinches the issue. ( 17 ) IN the case of THE STATE OF GUJARAT vs CHATURBHUJ MAGANLAL, the Supreme Court was concerned with the question whether the notification issued under Section 2 (c) of the Immoral traffic in Women and Girls Act could be said to have sppcially empowered the concerned Magistrate of First class to try the offence under the Act in the area falling under his jurisdiction or can the notification be treated to be not specially empowering such magistrates, on the wordings of the said notification. Section 2 (c) defined a Magistrate to mean a District Magistrate, Sub-Divisional magistrate, First Class, specially empowered by the State government to exercise the jurisdiction under the Act. The notification in question which was issued under Section 2 (c) of the Act by the state Government empowered all the Judicial Magistrates of First class in the State by virtue of their office to try the offences under the act in the area of their respective jurisdiction. The question before the supreme Court was whether such a general notification earmarking the class of officers for discharging their functions under the Act as magistrates in the area of their respective jurisdictions could be treated to be effecting special empowerment or general empowerment. The accused contended that it was a general empowerment and not a special one. Rejecting that contention, the supreme Court speaking through SARKARIA, J. , made the following pertinent observations: "the term "specially" in the expression specially empowered" in section 2 (c) of the Immoral Traffic in Women and Girls Act must be taken to have reference to special purpose of the empowerment. The word quaiifies the word "empowered" and has been used in an attributive sense to highlight the special nature of the power. It does not convey the sense of contradistinction or contrast between "special" empowerment and "general" empowerment. All that this word signifies is the investment of some or all the Magistrates of First Class under the criminal P. C. In short the word "specially" connotes that it is the empowerment which is special and not the person. Thus considered special empowerment does not necessarily involve selection of individuals by name of ex officio from the Magistrates of the First Class. Thus considered special empowerment does not necessarily involve selection of individuals by name of ex officio from the Magistrates of the First Class. " the empowerment of all the Magistrates of the First Class, in one notification being Government Notification No. PPA/ 1257/ 84187/x of 22-7-1958 published in Bombay Government Gazette on 31-7-1958 empowering all Judicial Magistrates of First Class in the State by virtue of their office to try offences under the Act in the area of their jurisdiction must be held to be 'special' and not general. " the situation in the present case is almost identical. Section 15 (1) of the Act enables the Commissioner of Commercial Taxes to earmark officers to be treated as specially empowered for the purpose of exercising powers under Section 15. The Notification in terms earmarked class of such officers, Deputy Commissioners of commercial Taxes (Administration) empowering them to revise the orders of their subordinates functioning under their respective jurisdictions. Identical was the notification before the Supreme Court and once the Supreme Court has held that such a notification amounted to special empowerment and not general empowerment, it must necessarily be held that present Notification of 1981 also has specially empowered the said officers for the purpose of Section 15 (1 ). The Supreme Court in that Decision in terms has referred with approval the earlier Decision in ABDUL HUSSAINS' CASE, wherein it was observed that if the meaning of the words specially empowered were to be that which is canvassed by the appellant, Government should have issued separate notification for each of the Special Land acquisition Officers authorising them to individually perform the functions of Collector within their respective jurisdiction. That could have been done even by one notification authorising each of them to perform those functions within their respective jurisdictions. That such a notification would mean that the Government thereby appoints each of the Special Land Acquisition Officers to perform the functions of the collectors within their respective areas. Having referred to the aforesaid Decision of Abdul Hussain's case, in paragraph 26 it was observed that: "on parity of reasoning, it can be said that the empowerment of all the Magistrates of the First Class in the State under one notification by virtue of their office to try offences under the Act in the area of their respective jurisdiction, must be held to be "special" and not "general". Mr. Mr. Kamath, learned Counsel for the appellant in connection with the aforesaid Supreme Court Decision submitted that in that case office of the Magistrates was already contemplated by the Act, while in the present case, when Notification of 1981 was issued, there was no post of Deputy Commissioner as contemplated by the Act and that the said term came to be inserted in the Act for the first time in 1985. In our view, this distinction is without any real difference. As per Section 15 (1) of the Act, Commissioner is delegated the power to specially empower any officer of his choice to exercise the powers under section 15 (1 ). It cannot be disputed, Deputy Commissioner of commercial Taxes (Administration) functioning under the Karnataka sales Tax Act, 1957 was one of such officers. Even that apart, after 1985 the term Deputy Commissioner got defined by the Act itself. We are concerned with the operation of this Notification years thereafter when for the first time notice was issued by the delegate of the commissioner under Section 15 (1) on 22-7-1989. By that time, the deputy Commissioner of Commercial Taxes was an officer contemplated by the Entry Tax Act itself. Consequently, attempt on the part of Sri Kamath to distinguish the ratio of the aforesaid supreme Court Decision is of no avail to him. ( 18 ) ON a parity of reasoning therefore, we must hold that Notification of 1981 also confers special empowerment to the earmarked class of officers namely, the Deputy Commissioners of commercial Taxes (Administration) for discharging revisional jurisdiction in connection with the orders of their subordinates in their respective jurisdiction. As such the Notification cannot be said to be an instance of general empowerment and not special empowerment. ( 19 ) IT was alternatively contended by learned Counsel tor the appellant Sri Kamath, that even if it is held that Notification specially empowered the Deputy Commissioner of Commercial Taxes (Administration) to exercise powers under Section 15 (1), in 1981 when this Notification was issued there was no post of Deputy commissioner of Commercial Taxes (Administration) as defined under the Act. It is true that such a definition was inserted by Section 2 (3a) with effect from 10-9-1985. The said definition reads as under: 2 (3a) "deputy Commissioner" means the Deputy Commissioner of Commercial Taxes appointed under the Karnataka Sales Tax act, 1957. Mr. It is true that such a definition was inserted by Section 2 (3a) with effect from 10-9-1985. The said definition reads as under: 2 (3a) "deputy Commissioner" means the Deputy Commissioner of Commercial Taxes appointed under the Karnataka Sales Tax act, 1957. Mr. Kamath, learned Counsel for the appellant, also agreed that by the time notices were issued under Section 15 (1) by that officer, such an officer was contemplated by the Act. However, his grievance is that when the impugned order came to be passed on 22-7-1993, it was passed by Joint Commissioner of Commercial Taxes (Administration), who was not at all referred to in the Notification on 31-7-1981. Therefore, the Joint Commissioner of Commercial Taxes (Administration), cannot be said to be specially empowered officer by 'the Commissioner as per the Notification dated 31-7-1981. So far as this alternative contention of Sri Kamath is concerned, Sri Ramesh, learned Counsel appearing for the revenue heavily relied upon two decisions of the Supreme Court, AIR 1951 SC 318 and 1957 SC 790 for submitting that the notification which is a statutory notification issued under Section 15 (1) has to be read with the parent Act namely, the Entry Tax Act. That in the parent Act itself, the amendment was brought about by Karnataka Act 5/93 with effect from 4-2-1993 and by Section 2 sub-section (3) thereof, it was laid down by the Legislature that in Karnataka Tax on Entry of Goods Act, 1979 for the expressions "assistant Commissioner", "deputy Commissioner" and "joint Commissioner" wherever they occur, the expressions "deputy Commissioner", "joint Commissioner" and "additional commissioner" shall respectively be substituted. Therefore, according to Sri Ramesh, learned Counsel for the Revenue, the word "deputy commissioner" should be read as "joint Commissioner". ( 20 ) MR. Kamath, learned Counsel for the appellant tries to repel this submission by contending that this exercise will be permissible in connection with the Act and not with the Notification which was issued years back in 1981. That because of aforesaid amendment wherever the word "deputy. Commisioner" is found in the Act it may be read as "joint Commissioner", but that amendment does not contemplate simultaneous amendment of the term "deputy Commissioner" as employed in any Notification issued under Section 15 (1 ). To repel this contention, Mr. That because of aforesaid amendment wherever the word "deputy. Commisioner" is found in the Act it may be read as "joint Commissioner", but that amendment does not contemplate simultaneous amendment of the term "deputy Commissioner" as employed in any Notification issued under Section 15 (1 ). To repel this contention, Mr. Ramesh, learned Counsel for the revenue has relied upon the aforesaid two Decisions of the Supreme Court, which have taken the view that the statutory order has to be read as part of the act. ( 21 ) IN our view, the ratio laid down by these two Decisions cannot be of any avail to Mr. Ramesh, for the revenue for the simple reason that all that those Decisions have said is that once an exercise is authorised by the statute by following the procedure to issue orders and once such orders are issued in exercise of the delegated legislative function contemplated by the Act itself, such orders will have effect as if such exercise was permitted by the Act itself. We are not concerned with any such situation in the present case. A short question for our consideration is when the Notification of 1981 issued by the Commissioner under Section 15 (1), specially empowers the deputy Commissioner of Commercial Taxes (Administration) to exercise powers under Section 15 (1), whether the term Deputy commissioner employed by the said Notification is automatically to be read as Joint Commissioner of Commercial Taxes by virtue of Section 2 (3) of the Karnataka Amendment Act 5/93. So far as this question is concerned, the aforesaid Decisions of the Supreme Court cannot assist the learned Counsel for the Revenue. ( 22 ) HOWEVER, Mr. Ramesh, learned Counsel for the Revenue rightly placed reliance on Section 20 of Karnataka General Clauses act, 1899. The said Section reads as under:"20. Construction of orders, etc. issued under enactments.- where, by any enactment, a power to issue any notification, order, scheme, rule, form or bye-law is conferred, then expressions used in the notification, order, scheme, rule, form or bye-law, if it is made after the commencement of this Act, shall, unless there is anything repugnant in the subject or context, have the same respective meanings as in the enactment conferring the power. "under Section 15 (1) of the Act, the power is conferred on the commissioner to issue notification. That power is exercised by him in 1981. "under Section 15 (1) of the Act, the power is conferred on the commissioner to issue notification. That power is exercised by him in 1981. While exercising that power, he has specially conferred revisional powers under Section 15 (1) on Deputy Commissioner of commercial Taxes (Administration ). The expression Deputy commissioner of Commercial Taxes, must, therefore get the same meaning as in the enactment namely, the Entry Tax Act conferring that power. Under the Entry Tax Act, which conferred this power, by virtue of its amendment by Act 5/93 as per Section 2 sub-section (3) of the Karnataka Act it has clearly been laid down that wherever the expression Deputy Commissioner is found in the Act, the said words should be read as Joint Commissioner. If in the parent Act the expression Deputy Commissioner is to be read as Joint commissioner then by virtue of Section 20 of the General Clauses Act even in the notification the expression Deputy Commissioner will have to be read as the expression Joint Commissioner. We do not find anything repugnant in the subject or context to take a different view. Consequently, applying Section 20 of the Karnataka General Clauses act to the facts of the present case, it must be held that after coming into operation of Karnataka Act 5/93 with effect from 4. 2. 1993, notification of 31. 7. 1981 will have to be read as specially authorising the Joint Commissioner of Commercial Taxes (Administration) to exercise powers conferred under Section 15 (1) of the Act in regard to the orders passed by officers subordinate to him in his jurisdiction. Consequently, the order passed by the Joint Commissioner of commercial Taxes (Administration) on 22. 7. 1993 cannot be said to have been passed by an unauthorised officer, who is not within the contemplation of the Notification of 31. 7. 1991, Alternative contention canvassed by Sri Kamath, on this aspect also has, therefore, to be rejected. 22a. Then remains the next question on the aspect of jurisdiction as to whether the Notification issued by the State of Karnataka in exercise of its power under Section 12 (1) on 19. 1. 1993/22. 4. 7. 1991, Alternative contention canvassed by Sri Kamath, on this aspect also has, therefore, to be rejected. 22a. Then remains the next question on the aspect of jurisdiction as to whether the Notification issued by the State of Karnataka in exercise of its power under Section 12 (1) on 19. 1. 1993/22. 4. 1993 has any effect on the revisional proceedings pending before the Joint commissioner of Commercial Taxes, Bangalore and whether these proceedings stood transferred by virtue of the aforesaid Notification to additional Commissioner of Commercial Taxes, Bangalore City one-l and consequently, whether the Joint Commissioner could not have passed the order on 22. 7. 1993. ( 23 ) SO far as this question is concerned, it must be kept in view that under Section 15 (1) as it stood on 22. 7. 1993, the Legislature has clearly indicated three authorities which would exercise powers under that Section, namely, 1) Commissioner, 2) Additional Commissioner, and 3) Any other Officer specially empowered by the Commissioner. Under the Notification of 1. 981, Joint Commissioner of Commercial taxes (Administration) would be said to be an officer specially empowered under Section 15 (1) to pass appropriate orders. This third category of specially empowered officer derives its efficacy and existence from the exercise of delegated legislative function by the commissioner himself and it cannot be touched by any authority exercising delegated functions under any other provisions of the Act. It is in the background of this statutory scheme of Section 15 (1) that we have to analyse the scope and ambit of the Notification dated 19. 1. 1993/22. 4. 1993. It will be profitable to reproduce the said notification in extenso at this stage. "si. No. 43 notification no. FD 336 CSE 92 (M), Bangalore, dated 19th January, 1993 SO 399, Karnataka gazette, dated 22nd April, 1993 in exercise of the powers conferred by sub-section (1) of section 12 of the Karnataka Tax on Entry of Goods Act, 1979 (Karnataka Act 27 of 1979) and in supersession of all previoust notifications/order issued in this regard the Government of karnataka hereby empowers the officers specified in column 2 of the Table below with Head quarters specified in column 3 to exercise the powers under Section 15 of the said Act in respect of the dealers falling in the areas specified in column 4 thereof: