Judgment :- THANIKKACHALAM, J. The department is the petitioner. While completing the original assessment for the year 1974-75, the assessing authority levied tax on the first sales of hides and skins falling under entry 7(b) of Schedule II of the Tamil Nadu General Sales Tax Act at 1(1/2) per cent. at single point. The Additional Deputy Commissioner considered that the levy of 1(1/2) per cent. on the first sales of hides and skins is to be taxed at 3 per cent. Therefore, the Additional Deputy Commissioner, came to the conclusion that the order passed by the assessing authority in levying tax at 1(1/2) per cent. is erroneous and prejudicial to the assessing officer under section32 of the Tamil Nadu General Sales Tax Act, 1959 (hereafter referred to as "the Act"). The Additional Deputy Commissioner after issuing notice to the assessee and after hearing the objections raised by the assessee, levied tax the sales of hides and skins at 3 per cent. Aggrieved, the assessee filed an appeal before the Appellate Tribunal. The Appellate Tribunal held that the order of the assessing authority does not suffer from any legal or procedural infirmity as first sales of hides and skins is liable to tax under entry 7(b) of Schedule II of the Act. Thus the Tribunal ultimately held that there is no cause action for the Additional Deputy Commissioner for setting aside the order of the assessing authority. The Tribunal has also held that the Additional Deputy Commissioner cannot sit himself in the armed chair of the assessing authority and pass an order of assessment. It was therefore ultimately held that the Additional Deputy Commissioner has no jurisdiction to revise the assessment under section32 of the Act. 2. It is against this order, the department is in revision before this Court. The learned Government Advocate (Taxes) submitted that the Additional Deputy Commissioner has got ample powers under section32 of the Act to revise the assessment. It was further submitted that on the newly gathered materials, it is open to the Additional Deputy Commissioner to direct the assessing authority to make fresh assessment. The learned Government Advocate (Taxes) submitted that the Additional Deputy Commissioner has got ample powers under section32 of the Act to revise the assessment. It was further submitted that on the newly gathered materials, it is open to the Additional Deputy Commissioner to direct the assessing authority to make fresh assessment. It was also submitted that the limitation period as contemplated under section16(1) of the Act do not apply in the case where the Additional Deputy Commissioner exercised his jurisdiction under section 32 of the Act, because according to the learned Government Advocate both the sections are independent and operating in a different field. It was submitted that in the present case the Additional Deputy Commissioner has merely recast the assessment and did not introduce any new addition. In support of this contention, reliance was placed on the decisions reported in -1. Ram Kanai Jamini Ranjan Pal Pvt. Ltd. v. Member, Board of Revenue, West Bengal. 2. State of Kerala v. K. M. Cheria Abdulla and Company and 3. A decision of this Court rendered in Venkateswara Metal Industries v. State of Tamil Nadu. 3. On the other hand, the learned counsel appearing for the assessee while supporting was made correctly with regard to the hides and skins by the assessing authority, there is no ground for interference by the Additional Deputy Commissioner under section 32 of the Act. Again it was submitted that the submitted that the Additional Deputy Commissioner under section 32 of the Act cannot make an assessment by himself. It was therefore submitted that the Additional Deputy Commissioner has got no jurisdiction to interfere with the order passed by the assessing officer in levying tax on the first sale of the hides and skins, which comes under entry 7(b) of Schedule II of the Act. 4. We have heard the rival submissions. The fact remains that in the original assessment, the assessing officer on the first sales of hides and skins levied tax at 1(1/2) per cent. since the goods fall under entry 7(b) of Schedule II of the Act. According to the Additional Deputy Commissioner, the tax leviable on hides and skins is 3 per cent. and not 1(1/2) per cent. and hence he exercised his jurisdiction under section 32 of the Act and revised the assessment by levying tax at 3 per cent. on the abovesaid goods. According to the Additional Deputy Commissioner, the tax leviable on hides and skins is 3 per cent. and not 1(1/2) per cent. and hence he exercised his jurisdiction under section 32 of the Act and revised the assessment by levying tax at 3 per cent. on the abovesaid goods. On the merits, so far as the levy of tax on the first sale of hides and skins is concerned, since this item of goods fall under entry 7(b) of schedule II of the Act, there is no infirmity in the assessment made by the assessing officer. 5. In so far the order passed by the Additional Deputy Commissioner is concerned, while passing the order, the Additional Deputy Commissioner issued notice to the assessee calling for the objections. After considering the objections. The Additional Deputy Commissioner recast the assessment and levied tax at 3 per cent. on the first sales of hides and skins. It is well established that the Additional Deputy Commissioner while exercising his jurisdiction under section32 of the Act, it is not possible for him to make a reassessment by himself. 6. In Ram Kanai Jamini Ranjan Pal Pvt. Ltd v. Member, Board of Revenue, West Bengal [1976] 38 STC, cited supra, the Supreme court, while considering the provision of section 14(1) and 20(3) of the Bengal Finance (Sales Tax) Act and rule 80A of the Rules, held as under : "The purposes of this Act are twofold, viz, the levy of a general tax on the sale goods to supplement the lost revenues and for promoting the general public good; and secondly, to see that this is done under the provisions of the Act and not by carrying out in a capricious or arbitrary manner. Therefore, a revisional authority has to be created. What is revision ? The essence of revisional jurisdiction lies in the duty of the superior Tribunal or officer entrusted with such jurisdiction to see that the subordinate Tribunals or officers keep themselves within the bounds prescribed by law and that do their duty requires them to do and that they do it in a legal matter. This jurisdiction being one of superintendence and correction in appropriate cases, it is exercisable even suo motu as is clear from the numerous statutory provisions to revision found in various Acts and Regulations such as the Civil Procedure Code, Criminal Procedure Code, Income-tax Act, etc. This jurisdiction being one of superintendence and correction in appropriate cases, it is exercisable even suo motu as is clear from the numerous statutory provisions to revision found in various Acts and Regulations such as the Civil Procedure Code, Criminal Procedure Code, Income-tax Act, etc. The jurisdiction of suo motu revision is not cribbed and cabined or confined by conditions and qualifications. The purpose of such an amplitude being given suo motu revisions appears to be as much to safeguard the interest of the exchequer as in the intersts of the assessee. The State can never be the appellant and if there is an order against the State to its prejudice, and naturally the assessee in whose favour the order is passed does not prefer an appeal, the State would suffer unless its intersts are safeguarded by the exercise of such supervisory jurisdiction as the one given to the authorities abovementioned." * Again in State of Kerala v. K. M. Cheria Abdulla and Company while considering the provisions of section 12, 19 of the Madras General Sales Tax Act, 1939 and rule 14-A of the Madras General Sales Tax Rules, 1939, the Supreme Court held as under : "..... It would not invest the revising authority with power to launch to upon enquiries at large so as either to trench upon the powers which are other expressly reserved at large so as either to trench upon the power which are expressly reserved at large by the Act or by the Rules to other authorities or to ignore the limitations inherent in the exercise of those powers. For instance, the power to reassess escaped turnover is primarily vested by rule 17 in the assessing officer and is to be exercised subject to certain limitations, and the revising authority will not be competent to make an enquiry for reassessing a taxpayer. Similarly the power to make a best judgment assessment is vested by section 9(2)(b) in the assessing authority and has to be exercised in the manner provided. It would not be open to the revising authority to assume that power. The revisional power has to be exercised for ascertaining whether the order passed is illegal or improper or the proceeding recorded is irregular and it is in aid of that power that such orders may be passed as the authority may think fit. It would not be open to the revising authority to assume that power. The revisional power has to be exercised for ascertaining whether the order passed is illegal or improper or the proceeding recorded is irregular and it is in aid of that power that such orders may be passed as the authority may think fit. One of the inquiries in considering the legality or property of the orders passed by the subordinate officer which the revising or the appellate authority may make is about the correctness of the tax levied and it after perusing the record the authority is prima facie satisfied about the illegality or impropriety of the order or about the irregularity of the proceeding, it may in passing its order direct an additional enquiry. Neither section 12 nor rule 14-A authorises the revising authority to enter generally upon enquiries which may properly be made by the assessing authorities and to reopen assessments." * Similarly the Madras High Court in A. Velayutha Raja v. Board of Revenue (C.T.), Madras-5 held that in passing an original order of assessment the Board exceeded its powers under section 345 and that the order was also passed beyond the time-limit. Therefore, the order was unenforceable in law. It was further held that the revisional powers exercised by the Board of Revenue under section 34 of the Madras General Sales Tax Act, 1959, are subject to the provisions of the Act and therefore a best judgment assessment or an original assessment by the Board under section 34 on the ground of escapement of turnover is bad in law and unsustainable. It is not a mere subjective satisfaction that is envisaged in section 34 but it should stand the test of objectiveness as also the prescribed guidelines set in the section itself and it should be in accordance with the order provisions of the Act. 7. The learned Government Advocate also brought to our notice a decision of this Court rendered in Venkateswara Metal Industries v. State of Tamil Nadu. According to the facts arising in this case, the original assessment was not revised under section 16 of the Act before that assessment was made subject to revision by the Board of Revenue in the said case unlike the cases cited in that decision. According to the facts arising in this case, the original assessment was not revised under section 16 of the Act before that assessment was made subject to revision by the Board of Revenue in the said case unlike the cases cited in that decision. This is a case of withdrawing the exemption by the Board of Revenue with respect to a turnover which was wrongly given by the assessing officer. Here the turnover has been already determined by the assessing officer. The question that was to be decided was whether the exemption granted by the assessing officer with respect to certain turnover was legally correct. Therefore, that decision was rendered on the facts available on record. Following the decisions of the Supreme Court in (State of Kerala v. Cheria Abdulla and Company), (Ram Kanai Jamini Ranjan Pal Pvt. Ltd. v. Member, Board of Revenue) and the decision of this Court (Velayutha Raja v. Board of Revenue), we hold that the Additional Deputy Commissioner has got no jurisdiction to make an assessment after issuing notice and hearing the assessee. The question of limitation does not arise in the present case. The Additional Deputy Commissioner exceeded the jurisdiction under section 32 of the Act. Therefore, we find that there is no infirmity in the order passed by the Tribunal in setting aside the suo motu order passed by the Additional Deputy Commissioner under section 32 of the Act. In that view of the matter, the revision is dismissed. No costs.