S. B. MAJMUDAR, C. J. ( 1 ) THERE is no substance in this appeal. The appellant-assessee had brought certain goods within the municipal limits of Mysore Corporation and the question was whether these goods were liable to bear entry tax. The appellant's submission was that it has purchased these goods from a factory which is situated within the Corporation limits of Mysore; therefore no entry tax is liable to be paid so far as these goods are concerned. That was not accepted by the assessing authority - the Additional Assistant Commissioner of Commercial Taxes (Assessments) Mysore. But the Deputy Commissioner of Commercial Taxes (Appeals), Mysore Division, Mysore, who heard the appeal of the assessee took the view that M/s. Wood Resins, Mysore, from whom goods are purchased by the assessee is found to be situated within the local limits of Mysore Corporation and hence the exemption was allowed on the said purchases on the plea that the said purchases are made within the local limits of Mysore Corporation. ( 2 ) THE Joint Commissioner of Commercial Taxes (Legal), Karnataka, Bangalore, took the order of the Deputy Commissioner of Commercial faxes (Appeals), Mysore Division, Mysore, in suo motu revision under Section 15 of the Karnataka Entry Tax Act, 1979, ('the Act' for short) on the ground that the order of the Deputy Commissioner was prejudicial to the Revenue and show cause notice was issued to the appellant. It filed its objections to this show cause notice. Thereafter, as the jurisdiction of the Joint Commissioner was transferred to the Additional Commissioner of Commercial Taxes, Mysore Zone, Mysore, revisional powers also got transferred in connection with this disputed matter. ( 3 ) BEFORE the Additional Commissioner, appellant's representative appeared and submitted that they have already filed objections to the show cause notice at Bangalore before the Joint Commissioner and that appropriate orders can be passed on that basis considering those objections. Thereafter the Additional Commissioner has passed the impugned order dated 18-10-1993. The Additional Commissioner has opted that after receipt of the records from the Gommissioner's office, it was enquired into to find out from the City Municipal Corporation of Mysore City whether M/ s. Wood Resins has their factory within the local area and they are paying municipal tax to the Municipal Corporation. The Additional Commissioner has opted that after receipt of the records from the Gommissioner's office, it was enquired into to find out from the City Municipal Corporation of Mysore City whether M/ s. Wood Resins has their factory within the local area and they are paying municipal tax to the Municipal Corporation. A specific reply has been received from the Commissioner of Municipal Corporation stating that Hinkal area where the factory of M/s. Wood Resine was located is not paying municipal taxes and Municipal Corporation are not collecting the tax vide their letter No. . RGL. 38/93-94 which was received on 13-7-1993. Keeping in view that certificate, the Additional Commissioner came to the conclusion that as the appellant was purchasing these goods from a factory outside the limits of local area it was liable to pay entry tax on these goods. Consequently, the order of the Deputy Commissioner was set aside and the assessment order passed by the assessing authority was restored. It is this order which is brought under challenge in this appeal under Section 16 of the Act. ( 4 ) AT the outset, the learned counsel for the appellant submitted that the Additional Commissioner had no jurisdiction under Section 15 of the Act to pass any revisional order - firstly on the ground that the Deputy Commissioner of Commercial Taxes (Appeals), was not subordinate to him and secondly that this is to circumvent the provisions of Section 14 of the Act. So far as these contentions are concerned, it is interesting to note, that nowhere any discussion is found in the order under appeal, though while noting the objections the Additional Commissioner in the impugned order has mentioned that reliance is placed by the assessee on (1986) 61 STC 107 : (1986 Tax LR 2290) (Kent) (FB) (Mohamed Samiullah v. Commr. of Commercial Taxes ). But no further discussion is found in this connection by the Additional Commissioner himself. Therefore, assuming that this point was placed for consideration in the objections which are noted, we may deal with this point. Section 14 provides that any officer empowered by the State Government in this behalf or any other person objecting to an order passed by the appellate authority may appeal to the Appellate Tribunal within a period of sixty days from the date on which the order was communicated to him. Section 14 provides that any officer empowered by the State Government in this behalf or any other person objecting to an order passed by the appellate authority may appeal to the Appellate Tribunal within a period of sixty days from the date on which the order was communicated to him. Section 15 (1) provides that 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 interests 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. It becomes at once clear that Section 14 though gives right of appeal to the Tribunal, does not in any way cut down the powers of revision given under Section 15 of the Act if it is found that the orders are prejudicial to the revenue. That is a suo motu power which operates independently and apart from Section 14. In fact the Full Bench decision of this Court to which assessee himself made a reference before the Additional Commissioner in the case of Mohamed Samiullah (1986 Tax LR 2290) (Kant) (FB) supra while considering Section 22-A of the Karnataka Sales Tax Act, 1957, which confers revisional powers on the Commissioner to interfere with an order made by an appellate authority under Section 20 of that Act, held that when an officer holding the post of the Deputy Commissioner subordinate to the Commissioner, who is the head of the department, exercises the power under the Act, whatever be the nature of that power, be it original, appellate or revisional, the Commissioner is competent to revise that order. What is true of the Deputy Commissioner is also true of all other officers, that are subordinate to the Commissioner exercising their powers under the Act. What is true of the Deputy Commissioner is also true of all other officers, that are subordinate to the Commissioner exercising their powers under the Act. Section 22-A of the Act is self-contained and any limitation on the exercise of the power by the, Commissioner must necessarily be found that very provision and in no other. In view of this Full Bench decision therefore it cannot be urged that because there is an appellate power of the Tribunal under Section 14, the revisional power under Section 15 is in any way curtailed. So far as the contention that the Additional Commissioner could not have revised the order of the Deputy Commissioner is concerned, such a contention does not seem to have been placed for consideration of the Additional Commissioner and no such objection seems to have been raised. But even that apart, Section 15 confers revisional powers to the Commissioner or Joint Commissioner. As per Section 2 (4a) of the Act, "joint Commissioner" means the Joint Commissioner of Commercial Taxes appointed under the Karnataka Sales Tax Act, 1957 (Karnataka Act 14 of' 1957 ). He is obviously an officer who has higher in hierarchy when compared AIJ Deputy Commissioner. Additional Commissioner is also defined to mean Joint Commissioner as per Section 22-A of the Karnataka Sales Tax Act, 1957. Whether any person is a Joint Commissioner or Additional Commissioner, he is an authority who is different and higher than the Deputy Commissioner and is placed at par with the Commissioner. Under these circumstances, therefore, it must be held that either the Commissioner or Additional Commissioner or Joint Commissioner as the case may be being a higher officer when compared to the Deputy Commissioner can exercise the powers under Section 15 of the Act. Therefore, this objection is also found to be devoid of any merit. ( 5 ) THEN coming to the merits of the case, it was submitted that there was a certificate with the Deputy Commissioner - the appellate authority, as issued by the Corporation- of Mysore itself which showed that its territory is extended up to 8 K. Ms. and that on the basis of that certificate the authority came to the conclusion that this factory which was shown to have been located within 8 K. Ms. from Mysore City could be said to have been included within the municipal limits. and that on the basis of that certificate the authority came to the conclusion that this factory which was shown to have been located within 8 K. Ms. from Mysore City could be said to have been included within the municipal limits. So far as this aspect is concerned, the Additional Commissioner in revision has rightly found that the certificate issued shows that the boundary of Municipal Corporation extends to a distance of 8 K. Ms. but the appellate authority has not specifically found out whether the factory falls within this range or not. Therefore, on that basis the appellate authority could not have decided in favour of assessee. That made the authority to make further enquiry in exercise of power under Section 15 (1) and that enquiry revealed by letter which was received from the Corporation that this factory was not located within the municipal limits and, even that factory was not paying any municipal tax to the Corporation. The learned counsel for the assessee submitted that the Additional Commissioner could not have made such an enquiry because there was nothing on record of the appellate authority to suggest to that effect. All that Section 15 (1) requires is if the order of the appellate authority is found to be prejudicial to the revenue, then after following the procedure laid down therein, the Revisional Commissioner or the Joint Commissioner, if necessary, may 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, may pass appropriate orders. It is not that the Revisional Commissioner cannot hold further inquiry into the matter in issue. Under these circumstances, no fault can be found in the procedure followed by the Additional Commissioner is collecting further information in this connection. Then it was submitted that the certificate of the municipal authorities received on 13-7-1993 was not shown to the appellant and no opportunity was given to it to meet the same. After the revisional powers were transferred to the Additional Commissioner, all that the appellant's representative stated is that they have filed their objections in Bangalore and they have nothing more to say and appropriate orders may be passed. After the revisional powers were transferred to the Additional Commissioner, all that the appellant's representative stated is that they have filed their objections in Bangalore and they have nothing more to say and appropriate orders may be passed. Therefore, when the certificate was received on 13-7-1993 no effort was made by the appellant or its representative to ask for a copy of the certificate or for being given an opportunity to rebut the same. As that effort was not made, no grievance can be made in this appeal at this stage. No opportunity was sought to that effect by the appellant. Therefore, this submission is only an after thought. ( 6 ) LASTLY it was contended that the order in revision cannot go beyond the scope of show cause notice. There cannot be any dispute that the show cause notice- Annexure-B dated 11-9- 1991 was confined to the items mentioned in para 2 of the show cause notice which covered purchase of raw materials from a registered dealer viz. , M/s. Wood Resins. Therefore, it is obvious that the order of the Additional Commissioner will also be read in the fight of the items listed in para 2 of the show cause notice which the assessee had purchased from M/s. Wood Resins. It has nothing to do with any other items purchased from any other registered dealers who may be admittedly functioning within the limits of Mysore. The appeal is accordingly dismissed subject to, the aforesaid clarifications. Appeal dismissed. --- *** --- .