JUDGMENT S. RAJENDRA BABU, J. - Though this matter is listed for orders, as suggested by the learned counsel on both sides it is taken up for final hearing and is disposed of by the following order : 2. The Additional Commissioner of Commercial Taxes in exercise of his powers under section 22A of the Karnataka Sales Tax Act, 1957, initiated certain proceedings against an order made by the appellate authority in respect of assessment years 1982-83 and 1983-84. In response to the notice issued to the appellant it raised three objections : (1) That the initiation of the proceedings is barred by limitation. (2) That it is unable to reply to the notice as it has no books. (3) That the appellate authority has correctly passed the order. The revising authority did not consider the effect of these contentions, but summarily rejected the same stating that they are not tenable as is evident from the show cause notice. 3. The appropriate way of dealing with the matter is to consider the contentions raised by the party concerned particularly the question relating to the limitation which could not have been considered in the course of the show cause notice at all although the merits of the order passed by the appellate authority might have been considered. 4. In the circumstances, the order made by the Additional Commissioner of Commercial Taxes, Zone-II, Bangalore, cannot be sustained, the same is set aside and the matter shall stand remitted to the revisional authority for fresh consideration in accordance with law. Appeal allowed accordingly. Appeal allowed.