JUDGMENT Y. BHASKAR RAO, J. - This appeal is filed by the appellant assailing the order of the Additional Commissioner of Commercial Taxes revising the order of the appellate authority as well as the assessing authority and directing the Assistant Commissioner of Commercial Taxes, Challakere, to issue revised demand notice as observed in his order. 2. The facts of the case are, that the appellant is a dealer in groundnuts. The appellant purchased groundnuts during 1983-84. He sold the said groundnut to XL International at Delhi who is an exporter to Russia. The appellant filed his returns. The assessing authority has assessed the appellant holding that the purchase made by the petitioner/appellant in the State of Karnataka is liable to be taxed under the Karnataka Sales Tax Act, 1957. Assailing that the appellant filed an appeal before the appellate authority. The appellant contended that the purchase of groundnuts by him is during the course of transaction of export to foreign countries, therefore, he is exempted from payment of taxes. So, the assessing authority erred in taxing him. The appellate authority allowed the appeal and directed the assessing authority to refund the tax amount. Against that order, the revisional authority has called for the files and after examining the files, found that the purchase of groundnuts by the appellant in the State of Karnataka will not form part of the purchase during the course of export. Therefore, he is not exempted from payment of tax and he is liable to pay tax and further held that the sale by the appellant to the Delhi party is inter-State transaction and that the sale is not to a foreign buyer and proposed to levy Central sales tax without any "C" forms. That order is challenged in this appeal. 3. Learned counsel for the appellant contended that the purchase made by the appellant in the State of Karnataka is in the course of export to foreign buyer. Therefore, no tax can be levied and the same is exempted under article 286 of the Constitution of India. That order is challenged in this appeal. 3. Learned counsel for the appellant contended that the purchase made by the appellant in the State of Karnataka is in the course of export to foreign buyer. Therefore, no tax can be levied and the same is exempted under article 286 of the Constitution of India. Learned Government Advocate contended that what all exempted for the purpose of export to foreign country is a preceding sale or purchase to the export sale but not any earlier purchase or sale and it has been pointed out that this point has already been decided by the court holding that, except preceding export purchase, the purchase made by the vendor to a foreign buyer is not a purchase during the course of export. Therefore, the same is not exempted. 4. In view of the above contentions, the important question of law that arises for consideration is : "Whether the purchase made by a dealer for sale to an exporter for the purpose of further sale to the foreign country is exempted from payment of sales tax or not." 5. To appreciate the above contention, it is relevant to extract article 286, clause (b) of the Constitution of India, which reads as follows : "286. Restrictions as to imposition of tax on the sale or purchase of goods. - (1) No law of a State shall impose, or authorise the imposition of, a tax on the sale or purchase of goods where such sale or purchase takes place - (a) ................. (b) in the course of the import of the goods into, or export of the goods out of, the territory of India." 6. Section 5(3) of the Central Sales Tax Act has been provided in tune with clause (b) of article 286 of the Constitution of India, which reads as follows "5. When is a sale or purchase of goods said to take place in the course of import or export. - (1) .............. (2) .............. Section 5(3) of the Central Sales Tax Act has been provided in tune with clause (b) of article 286 of the Constitution of India, which reads as follows "5. When is a sale or purchase of goods said to take place in the course of import or export. - (1) .............. (2) .............. (3) Notwithstanding anything contained in sub-section (1), the last sale or purchase of any goods preceding the sale or purchase occasioning the export of those goods out of the territory of India shall also be deemed to be in the course of such export, if such last sale or purchase took place after, and was for the purpose of complying with, the agreement or order for or in relation to such export." 7. By reading clause (b) of article 286 of the Constitution of India and sub-section (3) of section 5 of the Central Sales Tax Act, it is evident that the sale or purchase preceding the export sale is exempted from payment of sales tax. 8. In the present case, the appellant purchased groundnut from the unregistered dealer in the State of Karnataka. He sold it to a party, i.e., XL International at Delhi, who, in turn, exported the same to Russia. Therefore, the sale made by the appellant to the party at Delhi and the purchase by the party at Delhi is a preceding sale or purchase as contemplated under sub-section (3) of section 5 of the Central Sales Tax Act, which is in tune with clause (b) of article 286 of the Constitution of India. Therefore, these two transactions only form part of sale and purchase transaction during the course of export to a foreign country, but the purchase made by the appellant in the State of Karnataka from unregistered dealers is not a preceding purchase. Therefore, the appellant is not exempted from payment of sales tax. In this view of the matter, learned single Judge of this Court in Jayalaxmi Industries v. Deputy Commissioner of Commercial Taxes (Assessments), Tumkur [1996] 103 STC 182, has elaborately considered the scope and breadth of the exemption provided for the sales and purchases during the course of export and import and held that, except preceding sale and purchase, the other purchase and sales are not exempted from sales tax. We approve the said judgment. 9. We approve the said judgment. 9. Learned counsel for the appellant secondly contended that the revisional authority exercised power after expiry of the limitation. Limitation prescribed is four years under section 22A of the Karnataka Sales Tax Act. In this case, the appellate authority passed an order on November 16, 1994 and the assessment order was passed on September 26, 1987. Notice was issued on April 22, 1994 to the appellant. The limitation has to be counted from the date of initiation of proceedings but not from the date of issuing of notice. In this case, proceedings are initiated on July 16, 1990. Therefore, if the date of initiation of the proceedings is taken, the exercise of the powers is within the limitation. Our view was fortified by the judgment in S. Subba Rao v. Commissioner of Commercial Taxes in Mysore, Bangalore [1967] 19 STC 257 (Mys), wherein, a division Bench of this Court held that for the purpose of counting limitation, date of initiation must be taken into account for the purpose of examining whether the power is exercised within the limitation or not as contemplated under section 22-A(4) of the Sales Tax Act. Therefore, we are not able to agree with the contention of the learned counsel for the appellant. 10. It is thirdly contended by the learned counsel for the appellant that the revisional authority has set aside the orders of both the appellate authority and assessing authority, whereas, as per section 22-A of the Karnataka Sales Tax Act it must be set aside in one side and not both. To appreciate this, it is relevant to extract section 22-A of the Karnataka Sales Tax Act, which reads : "22-A. Revisional powers of Additional Commissioner and Commissioner. To appreciate this, it is relevant to extract section 22-A of the Karnataka Sales Tax Act, which reads : "22-A. Revisional powers of Additional Commissioner and Commissioner. - (1) The Additional Commissioner may on his own motion call for and examine the record of any proceeding under section 20 or section 21 of this Act and if he considers that any order passed therein by any officer who is not above the rank of a Joint Commissioner, is erroneous in so far as it is prejudicial to the interest of the Revenue, he may, if necessary, stay the operation of such order for such period as he deems fit 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 or directing a fresh assessment. (2) The Commissioner may on his own motion call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by any officer subordinate to him is erroneous in so far as it is prejudicial to the interest of the Revenue, he may, if necessary, stay the operation of such order for such period as he deems fit 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 or directing a fresh assessment. (3) to (5) ................." 11. By reading the abovesaid section, it is evident that it can be interpreted that the revisional authority can set aside only the order of one authority. However, it is to be noticed, where both the assessing authority and appellate authority pass concurrent orders and the revisional authority set aside the orders, both the orders will go by virtue of exercise of revisional powers. If the interpretation put forth has to be accepted, then only the order of the appellate authority will go while the order of the assessing authority remains. If the interpretation put forth has to be accepted, then only the order of the appellate authority will go while the order of the assessing authority remains. Therefore, we hold that the revisional authority has got the power to set aside the order of the appellate authority as also the assessing authority where the orders are concurrent and also set aside any one of the order if it is otherwise. In view of the above facts and circumstances, we see no merits in the contention of the learned counsel for the appellant. Accordingly, we confirm the order of the revisional authority and the appeal is dismissed. Appeal dismissed.