JUDGMENT S. B. SINHA, J. A short but interesting question of law as regards interpretation of sub-section (2-A) of section 20 of the Andhra Pradesh General Sales Tax Act, 1957 (for short, "the Act") arises for consideration in these writ petitions. All these writ petitions were filed by M/s. Indo National Ltd., Nellore, a company incorporated under the Companies Act, 1956. It is a registered dealer under the Act as also under the Central Sales Tax Act. It is engaged in the manufacture and sale of dry battery cells of different sizes, which are mostly used for torchlights, transistors, calculators, etc. It has depots or branches at various places in different States throughout the country. Apart from effecting local sales within the State of Andhra Pradesh, the petitioner also sells the goods in the course of inter-State trade as well as by effecting sales outside the State of Andhra Pradesh through its branches and depots. The goods are sent on stock transfer from the petitioner's factories in Nellore district to the concerned branches and the branches sell the goods to the authorised wholesale dealers. For the assessment years 1978-79, 1979-80 and 1980-81, the assessments were completed by the Commercial Tax Officer (CTO) excluding the branch transfers from taxation, but the Deputy Commissioner of Commercial Taxes, Nellore issued show cause notices on November 14, 1985 proposing to treat stock transfers as inter-State sale. Show cause notices were also issued proposing to assess branch transfers as inter-State sales for the assessment years 1981-82 and 1982-83. The Deputy Commissioner revised the orders of assessment for the years 1978-79, 1979-80 and 1980-81 levying tax on branch transfers and similar orders were passed by the CTO, Nellore for the years 1981-82 and 1982-83. Pursuant to the interim directions of the Supreme Court, the petitioner filed appeals to the Sales Tax Appellate Tribunal against the revisional orders passed by the Deputy Commissioner and also filed appeals against the consequential orders of the CTO before the Appellate Commissioner (Appeals). The Tribunal allowed the appeals by order dated June 19, 1992 and by reason of the said orders, the Appellate Deputy Commissioner allowed the petitioner's appeals on July 16, 1992 for the years 1981-82, 1982-83, 1983-84, 1984-85, 1985-86 and on July 20, 1992 for the year 1987-88. Thereafter, the Commissioner of Commercial Taxes (CCT), issued show cause notices in CCTs Ref. Thereafter, the Commissioner of Commercial Taxes (CCT), issued show cause notices in CCTs Ref. No. LV(2)/709 to 714 of 1994 dated March 17, 1996 by reason whereof the Commissioner in exercise of the power under section 20(1) of the Act sought to revise the orders dated July 16, 1992 passed by the Appellate Deputy Commissioner in respect of the assessment years 1981-82 to 1987-88 relating to the alleged branch transfers on the ground that the orders passed by the Appellate Deputy Commissioner are incorrect and prejudicial to the interest of the Revenue. These show cause notices were challenged in the present writ petitions. The assessing authority held that the turnovers relating to the assessment years in respect of the alleged branch transfers were exigible to tax under the Central Sales Tax Act (for short, "the CST Act") as they relate to inter-State sales. The Appellate Deputy Commissioner relying on the order of the Tribunal referred to above took the view that they were branch transfers and therefore not exigible to tax under the CST Act. The said order was sought to be revised by the Appellate Commissioner by the impugned show cause notices on the following grounds : 1. Extensive enquiries by the department revealed that the so-called branch transfers were only cover-up for actual inter-State sales. 2. The agreements between the respondent and some outside buyers clearly establish that the goods under dispute were supplied from their factory in TADA (Nellore District). Clause (17) of the agreement clinches this issue. From this it is very clear that the respondent clearly effected "inter-State sales" and to show them as "branch transfers" obtained the statutory "F" forms from the other State buyers. 3. Mere production of "E" form did not conclusively prove that a particular transaction is a branch transfer. The petitioner in these petitions contended that in relation to three earlier assessment years, the Sales Tax Appellate Tribunal agreed with the view of the Deputy Commissioner and held that the transactions were branch transfers and therefore not exigible to tax whereupon the contention of the Revenue that the alleged transactions are inter-State sales was negatived. It was further contended that against the orders passed by the Tribunal in respect of the assessment years 1978-79, 1979-80 and 1980-81, three revisions were filed which having been found to be barred by limitation, were dismissed and thus the appellate order had become final. It was further contended that against the orders passed by the Tribunal in respect of the assessment years 1978-79, 1979-80 and 1980-81, three revisions were filed which having been found to be barred by limitation, were dismissed and thus the appellate order had become final. In spite of the same, when show cause notices were issued couched in an identical language as in the case of the show cause notices impugned in the writ petitions herein, petitioner filed three writ petitions being W.P. Nos. 10416, 10417 and 10418 and a division Bench of this Court by order dated November 28, 1996 (Reported as Indo National Ltd. v. Commissioner of Commercial Taxes [2003] 133 STC 72) allowed the writ petitions holding as follows : "........... the authorities cannot take any action on the supposition that the judgment of the Tribunal is under consideration by this Court in any tax revision case. The impugned notices are also liable to be set aside on another ground. Under section 20(2-A) of the Andhra Pradesh General Sales Tax Act, revisional power cannot be exercised 'in respect of any issue or question which is the subject-matter of an appeal before, or which was decided on appeal by the Appellate Tribunal under section 21'. It therefore, follows that what has been decided by the Tribunal could not be in subject-matter for exercising revisional jurisdiction." The petitioners herein had raised a contention that in view of the aforementioned decision, the writ petitions should be allowed. When the writ petitions came up for hearing before a division Bench of this Court, the learned Government Pleader submitted that having regard to the provisions of sub-section (2-A) of section 20 of the Act, assessment in relation to subsequent years would not attract the bar of res judicata and thus revisional jurisdiction under sub-section (1) of section 20 can be invoked. In this connection, reliance has been placed on the decision of this Court in Minerals and Metals Trading Corporation of India Limited v. Deputy Commissioner, Commercial Taxes [1978] 42 STC 372, Pull Bench decision of this Court in State of Andhra v. Arisetty Sriramulu [1957] 8 STC 153 and a division Bench decision of this Court in Hyderabad Insulated Wires (P) Ltd. v. Commissioner of Commercial Taxes, Hyderabad [1991] 80 STC 99 (AP). In Minerals and Metals Trading Corporation of India Limited v. Deputy Commissioner, Commercial Taxes [1978] 42 STC 372, this Court held : "As regards the contention based on section 20(2-A) of the Andhra Pradesh General Sales Tax Act, it must be pointed out that, if the contentions of Mr. Dasaratharama Reddi regarding the interpretation which he wants us to place on sub-section (2-A) of section 20 were to he accepted, it would mean incorporating the principle of res judicata in sales tax matters. It is well-settled law that, so far as income-tax matters are concerned, the decision given in respect of one assessment year cannot be binding in respect of a subsequent assessment year on the same question and the same principle has been accepted in the context of sales tax law as well ............ section 20(2-A) of the Andhra Pradesh General Sales Tax Act cannot be so read as to bring in the concept of res judicata. The fact that, in appeal, any particular issue or question is either pending decision of the Tribunal or has already been decided by the Tribunal cannot operate as res judicata for other assessment years and cannot prevent the exercise of revisional powers by the Deputy Commissioner except in relation to the particular assessment year in respect of which an appeal is pending before the Sales Tax Appellate Tribunal or in respect of which the question or issue has been decided by the Tribunal. It should be borne in mind that, if the sales tax authorities are aggrieved by the issue or question decided by the Sales Tax Appellate Tribunal either in the appeal, which was pending at the time or in a particular appeal which has already been decided, they can always approach the High Court on a reference so that the matter can be ultimately decided or they can come to the High Court in the exercise of the revisional powers. Under these circumstances, this contention based on section 20(2-A) cannot help the petitioner." Doubting the correctness of the division Bench decision of this Court in Minerals and Metals Trading Corporation of India Limited v. Deputy Commissioner, Commercial Taxes [1978] 42 STC 372, the division Bench has referred these writ petitions to a larger Bench as to the interpretation of the sub-section (2-A) of section 20 of the Act. Sub-sections (1), (2) and (2-A) of section 20 of the Act read as under : "20. Revision by Commissioner of Commercial Taxes and other prescribed authorities. - (1) The Commissioner of Commercial Taxes may suo motu call for and examine the record of any order passed or proceeding recorded by any authority, officer or person subordinate to it, under the provisions of this Act, including sub-section (2) of this section and if such order or proceeding recorded is prejudicial to the interests of revenue, may make such enquiry, or cause such enquiry to be made and subject to the provisions of this Act, may initiate proceedings to revise, modify or set aside such order or proceeding and may pass such order in reference thereto as it thinks fit. (2) Powers of the nature referred to in sub-section (1) may also be exercised by the Additional Commissioner or the Joint Commissioner, Deputy Commissioner, Assistant Commissioner and the Commercial Tax Officer in the case of orders passed or proceedings recorded by authorities, officers or persons subordinate to them. (2-A) The power under sub-section (1) or sub-section (2) shall not be exercised by the authority specified therein in respect of any issue or question which is the subject-matter of an appeal before, or which was decided on appeal, by the Appellate Tribunal under section 21." Sub-section (1) of section 20 is no doubt of wide amplitude. But the revisional power of the Commissioner in terms of sub-section (1) or sub-section (2) is sought to be curtailed by reason of sub-section (2-A). The phraseology used in sub-section (2-A) of section 20 of the Act is absolutely clear and unambiguous, in terms whereof, a bar has been created to entertain any application in respect of any "issue or question" which was the subject-matter of an appeal or which was decided in appeal by the Appellate Tribunal under section 21. There cannot be any dispute that in the hierarchy of authorities provided for under the Act, the Appellate Tribunal is superior to the Commissioner of the Commercial Taxes. There cannot be any dispute that in the hierarchy of authorities provided for under the Act, the Appellate Tribunal is superior to the Commissioner of the Commercial Taxes. Irrespective of the fact that as to whether principles of res judicata will be applicable or not, we are of the opinion that the said provision creates a bar in the exercise of the revisional jurisdiction by the Commissioner if the issue or question has already been decided by the Appellate Tribunal in relation to the earlier assessment year. A distinction must be borne in mind that had the intention of the Legislature been otherwise, the same could have been specified in explicit language as was done in section 264(4)(c) of the Income-tax Act. The words "issue or question" are of wide amplitude. An issue or question may arise in relation to the selfsame, assesses in respect of any assessment year or it may arise after some years in relation to some other assessee. If such issue or question was the subject-matter of appeal before the Appellate Tribunal or if it had been decided by the Appellate Tribunal under section 21, evidently, on a plain reading of sub-section (2-A) of section 20, the same cannot be the subject-matter of revision under sub-section (1) of section 21 of the Act. Furthermore, judicial and administrative discipline demands that inferior authority must act in terms of the decision of a superior authority. In Bhopal Sugar Industries Ltd. v. Income-tax Officer [1960] 40 ITR 618 (SC); AIR 1961 SC 182 , the Income-tax Officer, Bhopal has refused to carry out certain directions given by the Income-tax Appellate Tribunal, Bombay in an appeal preferred by the appellant-company therein. The Judicial Commissioner, Bhopal held that no manifest injustice resulted from the order of the Income-tax Officer declining to carry out the directions of the Tribunal. In that context, the apex Court held that the Income-tax Officer has failed to carry out a legal duty imposed on him and such failure was destructive of basic principle of justice. It was held : "We think that the learned Judicial Commissioner was clearly in error in holding that no manifest injustice resulted from the order of the respondent conveyed in his letter dated March 24, 1955. It was held : "We think that the learned Judicial Commissioner was clearly in error in holding that no manifest injustice resulted from the order of the respondent conveyed in his letter dated March 24, 1955. By that order the respondent virtually refused to carry out the directions which a superior Tribunal had given to him in exercise of its appellate powers in respect of an order of assessment made by him. Such refusal is in effect a denial of justice, and is furthermore destructive of one of the basic principles in the administration of justice based as it is in this country on a hierarchy of courts. If a subordinate Tribunal refuses to carry out directions given to it by a superior Tribunal in the exercise of its appellate powers, the result will be chaos in the administration of justice and we have indeed found it very difficult to appreciate the process of reasoning by which the learned Judicial Commissioner while roundly condemning the respondent for refusing to carry out the directions of the superior Tribunal, yet held that no manifest injustice resulted from such refusal." Dharam Chand Jain v. State of Bihar AIR 1976 SC 1433 was a case where the Central Government in exercise of its revisional jurisdiction under rule 54 of the Mineral Concession Rules, 1960 allowed the revision application filed by the appellant therein but the State Government declined to implement the same. The Supreme Court held : "......... there was absolutely no legal justification at all for the Central Government to go back upon its earlier order. The earlier order of the Central Government stood unvaried and unvacated and the State Government was bound to implement it and, therefore, the Central Government was in error in upholding the action of the State Government rejecting the revision application filed by the appellant and thus silently condoned the lapse committed by the State Government." We may now consider the decisions cited by the learned counsel appearing for the State. In State of Andhra v. Arisetty Sriramulu [1957] 8 STC 163 a Full Bench of the Andhra High Court was considering the provisions of section 12-A(6)(a) of the Madras General Sales Tax Act. The question which was referred to the Full Bench was what is the correct interpretation of section 12-A(6)(a) of the Madras General Sales Tax Act. In State of Andhra v. Arisetty Sriramulu [1957] 8 STC 163 a Full Bench of the Andhra High Court was considering the provisions of section 12-A(6)(a) of the Madras General Sales Tax Act. The question which was referred to the Full Bench was what is the correct interpretation of section 12-A(6)(a) of the Madras General Sales Tax Act. The power of review and power of revision are not identical. In that case it was held that rule 18(I) was wider than order 47, rule 1 of the Code of Civil Procedure. It was held that the mistake could be rectified irrespective of how it occurred or whether it relates to an issue of fact or a point of law. As regards the applicability of principles of res judicata, however, the Full Bench observed : "There is no doubt some authority for this proposition. We are here concerned with the interpretation of a specific statutory provision empowering the Appellate Tribunal to grant a review and not with the inherent powers, if any, of the Tribunal. Reference was also made to the provisions of Order 20, rule 3, Civil Procedure Code, to the effect that a judgment once pronounced and signed could not be altered or added to except as provided by section 152 or on review. It is the power of review given by section 12-A(6)(a) of the Act that is invoked here to modify the previous order of the Appellate Tribunal. Moreover, an order of assessment or an order of the Appellate Tribunal on appeal fixing the liability to tax in a particular year does not operate as res judicata or estoppel so as to prevent that decision from being reopened in assessments for subsequent years. Compare Commissioner of Income-tax v. Massey & Co. [1929] 56 MLJ 451. Even in respect of the same year's assessment, power is given to the assessing authority to bring under assessment any turnover that might have escaped tax at the time when the order of assessment was made. See rule 17 of the Madras General Sates Tax Rules. Therefore, it is not right to treat an order of assessment to sales tax as it stood on the same footing as the judgment of a court in every respect." The said decision has no application to the facts Of the present case. See rule 17 of the Madras General Sates Tax Rules. Therefore, it is not right to treat an order of assessment to sales tax as it stood on the same footing as the judgment of a court in every respect." The said decision has no application to the facts Of the present case. In Instalment Supply (Privats) Ltd. v. Union of India [1961] 12 STC 489 the apex Court while considering the definition of "sale" in the Bengal Finance Sales Tax Act, 1941 as extended to Delhi observed that in matter of tax there is no question of res judicata because each year's assessment is final only for that year and does not govern later years, because it determines only the tax for a particular period. The question, which has arisen for consideration before us, had not arisen before the apex Court. In Doma Sao Mohanlal v. State of Bihar [1971] 27 STC 473, the apex Court while considering the provisions of the Bihar Sales Tax Act, 1944, observed that the decision of the High Court on a writ petition in relation to the assessment year 1949-50 could not be relied on in relation to the recovery proceedings for periods ending March 31, 1947, since each assessment period was distinct and any decision of the authorities declaring liability to tax could not operate as res judicata in respect of another period. In that case, the Supreme Court remitted the matter to the High Court for an investigation whether the appellant therein was a transferee to whom the ownership of the business of the Hindu undivided family was entirely transferred as no finding to that effect had been adverted to. In Hyderabad Insulated Wires (P) Ltd. v. Commissioner of Commercial Taxes, Hyderabad [1991] 80 STC 99 this Court held : "The idea underlying section 20(2-A) is to give finality and primacy to the decision of the Tribunal vis-a-vis an issue or question decided by the Tribunal in a lis between the same parties in respect of a particular period of assessment, subject, of course, to the result of a revision to the High Court. To construe it otherwise would lead to anomalous consequences. To construe it otherwise would lead to anomalous consequences. For instance, if the Appellate Tribunal has decided a particular issue or question in any case, it would for all the time to come, fetter the hands of the revisional authority from revising the order of the subordinate authority notwithstanding the fact that the High Court or Supreme Court had taken a contrary view subsequently. We have, therefore, no hesitation in rejecting the first contention of the petitioner." It was further held : "In the face of the reassessment order passed by the Commercial Tax Officer subjecting a part of the turnover to surcharge in addition to the tax already levied, it was unnecessary and in fact beyond the jurisdiction of the Deputy Commissioner to go back to the original assessment and adjudicate upon the legality or propriety of that assessment. The omission, if any, in the original assessment order to levy surcharge was filled up by the reassessment order which came into existence by the time the Deputy Commissioner took up the revision. The said reassessment order having been set aside on appeal by the appellate authority by his order dated January 16, 1987, the said order of the appellate authority holds the field as on today. Unless and until that order is disturbed by the revisional authority or otherwise, no surcharge can be demanded from the petitioner. The Commissioner has proceeded on an erroneous assumption that the revision of the order of the Deputy Commissioner would automatically pave the way for demand of surcharge under section 6-B. But in our view, this result does not follow in law. Firstly, the Deputy Commissioner could not have proceeded with the revision of original assessment order for the purpose of imposing surcharge when the surcharge was already levied by then by a reassessment order. Evidently, the Deputy Commissioner did not touch upon the revised assessment order at that time as he was under the mistaken impression that no reassessment was at all made in relation to surcharge. Secondly, the force and effect of the appellate order dated January 16, 1987 cannot be ignored by the Commissioner. In out view, so long as the order of the appellate authority stands, no demand for surcharge could be raised or directed to be raised. Secondly, the force and effect of the appellate order dated January 16, 1987 cannot be ignored by the Commissioner. In out view, so long as the order of the appellate authority stands, no demand for surcharge could be raised or directed to be raised. The desired effect of raising a demand for surcharge can only be brought about by revising the order of the appellate authority. But as the revision notice now stands, there is no such proposal. We, therefore, deem it fit to issue a writ prohibiting the Commissioner from proceeding with the levy of surcharge pursuant to the impugned notice. However, we leave it open to the Commissioner, if he so chooses to initiate fresh proceedings for the purpose of revising the order of the appellate authority dated January 16, 1987." It will, therefore, be seen that the said case was decided on the peculiar facts obtaining therein. We have earlier quoted the decision of a division Bench of this Court in Minerals and Metals Trading Corporation of India Limited v. Deputy Commissioner, Commercial Taxes [1978] 42 STC 372. With great respect, we do not agree with the observations made by the learned Judges in the said decision. As observed hereinbefore, it is not necessary that principles of res judicata must be read in the said provision. It merely creates a bar in the exercise of jurisdiction by the revisional authority. A question or issue may be on fact or in law. Where it involves a question or issue as of fact, the same may be held to be confined to that particular order and in relation to another assessment year, the fact may be different. But, if the issue or question relates to a point of law, the intention of the Legislature appears to be that the assessee should not be vexed on such question again and again. As indicated hereinbefore if a question or issue decided by the Appellate Tribunal is in conflict with the decision of the High Court or the Supreme Court, naturally, the latter will prevail. But unless so done, the Commissioner, on a plain reading of the aforementioned provisions, must be held to be bound by such decision of the Tribunal on question of law. A liberal meaning has normally to be attributed while interpreting a statute. In Sutters v. Briggs (1922) 1 Appeal Cases 1 the Privy Council held. But unless so done, the Commissioner, on a plain reading of the aforementioned provisions, must be held to be bound by such decision of the Tribunal on question of law. A liberal meaning has normally to be attributed while interpreting a statute. In Sutters v. Briggs (1922) 1 Appeal Cases 1 the Privy Council held. "There is indeed no reason for limiting the natural and ordinary meaning of the words used. The term 'holders or indorsees' means any holder and any indorsee, whether the holder be the original payee or a mere agent for him, and the rights of the drawer must be construed accordingly. The circumstance that the law apart from, the section in question was repealed in 1845, without any repeal of the section, itself, may lead to anomalies, but cannot have weight in construing the section." In Dental Counsel of India v. Hari Prakash (2001) 7 JT 342 (SC) it was held : "The intention of the Legislature is primarily to be gathered from the language used in the statute, thus paying attention to what has been said as also to what has not been said. When the words used are not ambiguous, literal meaning has to be applied, which is the golden rule of interpretation." In Dadi Jagannadham v. Jammulu Ramulu AIR 2001 SCW 3051 , the apex Court held : "The settled principles of interpretation are that the court must proceed on the assumption that the Legislature did not make a mistake and that it did what it intended to do. The court must, as far as possible, adopt a construction, which will carry out the obvious intention of the Legislature. Undoubtedly if there is a defect or an omission in the words used by the Legislature, the court would not go to its aid to correct or make up the deficiency. The court could not add words to a statute or read words into it which are not there, especially when the literal reading produces an intelligible result. The court cannot aid the Legislature's defective phrasing of an Act, or add and mend, and, by construction, make up deficiencies which are there." In Gurudevdatta VKSSS Maryadit v. State of Maharashtra (2001) 4 SCC 534 the apex Court held that the words used in a provision should be considered in the following terms : "........ The court cannot aid the Legislature's defective phrasing of an Act, or add and mend, and, by construction, make up deficiencies which are there." In Gurudevdatta VKSSS Maryadit v. State of Maharashtra (2001) 4 SCC 534 the apex Court held that the words used in a provision should be considered in the following terms : "........ it is a cardinal principle of interpretation of statute that the words of a statute must be understood in their natural, ordinary or popular sense and construed according to their grammatical meaning, unless such construction leads to some absurdity or unless there is something in the context or in the object of the statute to suggest to the contrary. The golden rule is that the words of a statute must prima facie be given their ordinary meaning. It is yet another rule of construction that when the words of the statute are clear, plain and unambiguous, then the courts are bound to give effect to that meaning, irrespective of the consequences. It is said that the words themselves best declare the intention of the law-giver." The court while considering a statute is only concerned with the legislative policy. Once the legislative policy is found to be clear and unambiguous, it cannot add any words therein to give a different meaning or to read the same in such manner as a result whereof a different meaning would be attributed. With great respect to the learned Judges, the division Bench in Minerals and Metals Trading Corporation of India Limited v. Deputy Commissioner Commercial Taxes [1978] 42 STC 372 (AP) has proceeded on the principle of res judicata but did not advert to the real question. The State can provide for a right of appeal or revision. The State can also create such a right to a party to the lis subject to fulfilment of some conditions. It can also grant a limited revisional power to a higher authority. The power of revision vested in the Commissioner being circumscribed under sub-section (2-A) of section 20 of the Act, something may not be read therein which would confer a wide power upon the Commissioner as a result whereof the purport and object of sub-section (2-A) would be defeated. It can also grant a limited revisional power to a higher authority. The power of revision vested in the Commissioner being circumscribed under sub-section (2-A) of section 20 of the Act, something may not be read therein which would confer a wide power upon the Commissioner as a result whereof the purport and object of sub-section (2-A) would be defeated. Under sections 10 and 11 of the Code of Civil Procedure, the expression "issue" acquires a distinct meaning and it confines to the question as to the point in controversy between the parties or their privies rather than the time factor. For the reasons aforementioned, we are of the opinion that the decision of this Court in Minerals and Metals Trading Corporation of India Limited v. Deputy Commissioner, Commercial Taxes [1878] 42 STC 372 does not lay down the correct law and must be overruled. It is accordingly overruled. The impugned notices dated March 17, 1996 issued by the Commissioner of Commercial Taxes are quashed and the writ petitions are allowed. There shall be no order as to costs. Writ petitions allowed.