Judgment :- Om Prakash, CJ. Heard counsel for the parties. 2. The only question for consideration arising from the Original Petition filed by the petitioner (appellant herein) was whether there was any "proceeding recorded" within the meaning of sub-s.(1) of S.36 of the Kerala General Sales Tax Act, 1963, enabling the petitioner (hereinafter referred to as the assessee ) to file revision under S.36 against Ext. P11 demand notice. 3. The assessee claimed refund of Rs. 23,364/-. By Ext. P3 order dated 6.7.1982 the said refund was ordered by the Sales-tax Officer (Enquiry) Later by Ext. P5 order dated 19.3.1983 adjustment of the refund due to the assessee was ordered. By Ext. P7 order dated 25.3.1983, the Assistant Commissioner (Assessment) II informed the assessee that the Sales-tax Officer IV Circle Kozhikode had been instructed to refund the amount of Rs. 23,364/-. it is contended by the assessee that refund order having been passed, he adjusted the amount of Rs. 23,364/- and filed return accordingly. Thereafter assessment was made without taking notice of Rs. 23,364/- being adjusted and demand was accordingly raised. It is further contended that pursuant to the assessment order Ext. P11, demand notice was issued regarding the demand of interest under S.23(3) of the Act. It is the contention of the assessee that he disputed the demand on the ground that refund of Rs. 23,364/- was allowed to him. But despite that the said amount was not adjusted in the assessment order and the interest demand was wrongly raised. 4. Aggrieved the assessee filed a revision under S.36, which was dismissed by the authority saying that there being no order or recorded proceedings, the revision was not maintainable under S.36. 5. The assessee then took up the matter before this Court in the Original Petition under Art.226 of the Constitution. The learned single judge also took the same view that there was neither any order nor any proceedings and therefore, the revision under S.36 was not maintainable. The Original Petition was accordingly dismissed. 6. We have carefully gone through Ext. P11 demand notice to which a note is appended as follows: "You have not paid the entire Tax and SC due for the month of September, 1983. You are therefore, liable to pay penal interest on the balance amount of Rs. 23,188/85 as worked out below. Bal. amount Rs. 6. We have carefully gone through Ext. P11 demand notice to which a note is appended as follows: "You have not paid the entire Tax and SC due for the month of September, 1983. You are therefore, liable to pay penal interest on the balance amount of Rs. 23,188/85 as worked out below. Bal. amount Rs. 23188-85 Delay since the issue of demand notice 25 months @ 47% Penal interest due Rs. 10898-75" Before us learned counsel for the assessee urges that there may not be any order, but surely the note appended to Ext. P11 demand notice, falls within the expression "proceedings recorded" occurring in sub-s, (1) of S.36 of the Act. In Governor-General in Council v. Shiromani Sugar Mills Ltd., AIR (33) 1946 Federal Court 16, the Count held that action on the part of the income tax authorities for recovery could amount to proceedings for the collection of arrears. The Concise Oxford Dictionary gives the meaning of the "proceeding" as used in the legal sense as step taken in legal action. In Oriental Gas Company Ltd. v. State of West Bengal (1973) 32 STC 141, the Calcutta High Court observed that the meaning that is given to the word "proceeding" occurring in one statute cannot he taken as a safe guide for ascertaining the true import of the word appearing in a different enactment. In some enactments this word means an action or that which initiates an action and in other enactments it may mean a step in an action. The Calcutta High Court further held that a proceeding under the Bengal Finance (Sales Tax) Act comprehends the whole procedure for the levy, assessment and collection of the tax liability of a dealer. By Ext. P11 demand notice, it is certain that the departmental authorities took steps to recover the liability determined as sales tax and that was duly recorded in the demand notice itself. Ordinarily, a demand notice does not record any proceeding. But in Ext. P11 demand notice, the Assistant Commissioner (Assessment), Sales Tax clearly recorded the proceedings to recover penal interest to the tune of Rs. 10898-75. The note appended to 'Ext. P11 demand notice was not seen or adverted to in the impugned judgment by the learned single Judge. It leaves no room for doubt that proceedings for recovery of penal interest were duly recorded in Ext. 10898-75. The note appended to 'Ext. P11 demand notice was not seen or adverted to in the impugned judgment by the learned single Judge. It leaves no room for doubt that proceedings for recovery of penal interest were duly recorded in Ext. P11 demand notice by means of the note appended thereto. 7. We, therefore, do not enter into the controversy whether there was any 'order' within the meaning of S.36, but we conclude the case saying that surely there are proceedings recorded within the meaning of S.36, which are fully reflected in the note, appended to Ext. P11 demand notice. We therefore, hold that revision was maintainable against the proceedings recorded in Ext. P11 demand notice itself under S.36 of the Act. In the result, the appeal succeeds and is allowed. The impugned judgment dated 13th January, 1994 and Ext. P12 order passed by the revisional authority are set aside and the case is remitted to the revisional authority to decide the matter afresh on merits.