M. F. SALDANHA, J. ( 1 ) THIS appeal is directed against an order dated May 27, 1997 of the revisional authority,. e. , additional Commissioner of Commercial Taxes, Mysore Zone, Mysore. The authority had set aside an appellate order of the Additional J. C. C. T, (Appeals), Bangalore dated June 30, 1994 and had restored the order of the assessing authority dated April 29, 1989. It is material to point out that the order in question concerned the assessment period July 1, 1985 to June 30, 1986. ( 2 ) WE shall refer only to a few of the relevant facts. The appellant is a registered dealer under the provisions of the Karnataka Sales Tax Act. He is a manufacturer of fenny which being sold by him in bottled and packed condition during the relevant period. The assessing authority levied the tax on the total turnover value of the fenny which included the packing material and disallowed the claim by the appellant for the value of the packing material. We need to straight away point out that the amendment to Section 5 of the Act whereby Sub-section (3-D) came to be inserted was effected on April 1, 1986 and that this appeal concerns the period prior to the date of the amendment. It is however necessary to clarify that since the appellant was following the co-operative year and not the financial year, that one part of the sales covers the period April 1, 1986 to June 30, 1986 which period will have to be excluded from the purview of this order. The reason for this is because after the amendment and particularly in view of the law as settled by the Supreme Court, no distinction can any longer be made with regard to the tax differential as far as the packaging material is concerned. ( 3 ) THE appellant's learned counsel submitted that there is a clear error on the part of the revisional authority in so far as according to him the authority has proceeded to revise an order passed by the appellate authority which order in turn was on the basis of a factual assessment. ( 3 ) THE appellant's learned counsel submitted that there is a clear error on the part of the revisional authority in so far as according to him the authority has proceeded to revise an order passed by the appellate authority which order in turn was on the basis of a factual assessment. Learned counsel had submitted that effectively, the scope of Section 22 (A) must necessarily be restricted to revising that class of orders wherein the authority concerned has effectively gone wrong on a point of law and it was his submission that these powers are not to be exercised for purposes of carrying out a reassessment. As far as this submission is concerned, we do not need to examin it in any effective detail. We do concede that the revisional powers which are invariably exercised, suo motu have been incorporated for purposes of taking corrective action in those of the cases where there has been effective miscarriage of justice which in turn has resulted in prejudice to the Revenue. While it is more or less a well-settled norm that such revisional powers would ordinarily be exercised in cases where there has been a misreading or misapplication of the law, we do need to clarify that there could arise a small category of cases where the earlier order has gone so cronically and basically into the arena of error or for instance where the order itself is virtually perverse. It may be that in some or several such instances the department on its own has not taken corrective action for a variety of reasons and it would therefore be wrong to lay down an inflexible rule that the revisional powers should exclude this category of cases. In the present instance, the grievance put forward by the learned counsel is reasonably well-founded because of the faulty reasoning or lack of supportive reasoning that manifests itself in the impugned order. ( 4 ) SECONDLY, the appellant's learned counsel raised a point of propriety wherein he drew our attention to the observations of the revisional authority who has refused to follow the decision of the Tribunal on the ground that the decision is not binding. ( 4 ) SECONDLY, the appellant's learned counsel raised a point of propriety wherein he drew our attention to the observations of the revisional authority who has refused to follow the decision of the Tribunal on the ground that the decision is not binding. The submission canvassed was that the Tribunal, in the hierarchy, necessarily is a higher authority than the Joint Commissioner and that consequently it would be incorrect and improper on the part of the Joint Commissioner to refuse to follow the decision of the Tribunal. The reason why this submission has been put forward is because the learned counsel pointed out that in respect of the same assessee pertaining to the earlier assessment years the Tribunal had decided in favour of the assessee relying on a clarification issued by the department itself and it is his submission that when this order was pointed out, the revisional authority was in error to have refused to follow it on the ground that it is not binding. All that we need to observe is that the word "binding" is perhaps too harsh an expression but it is a well-settled norm of procedure even in the judiciary that well-considered judicial orders particularly if they have emanated from a higher authority or court are invariably respected and if there is good reason for distinguishing that order or for not following it, then very cogent grounds must be set out therefor. It is a well-settled norm of procedure that where points have been decided or where after a thorough examination a finding has been recorded, that these orders should be respected much more so, by an authority of co-ordinate or inferior jurisdiction. Having regard to this position, the revisional authority was certainly in error in having summarily refused to follow the well-considered order passed by the Tribunal in respect of the very assessee for earlier assessment year when the facts were identical. ( 5 ) COMING to the real issue in controversy, what the appellant's learned counsel essentially submitted was that having regard to the state of the law as it existed prior to the amendment of section 5 (3-D) on April 1, 1986 that where the differential of tax arose with regard to the contents and the container and where this had been separately accounted for, that the distinction would hold good for purposes of assessment. It is true that the position materially altered after april 1, 1986 but the submission canvassed in the present case was that on facts, where the department had consistently accepted the position vis-a-vis this assessee that the contents and the container attracted tax at different rates that it was impermissible to impose a common rate of tax in respect of both of them. We have examined the statutory provisions prior to April 1, 1986 and thereafter but we do not consider it necessary to go into any elaborate reproduction because this high Court had occasion to consider a situation that arose under more or less identical circumstances in the case of State of Karnataka v. Shaw Wallace and Co. Ltd. ILR1981 KAR 940 , 1981 (2 )Karlj58 , [1981 ]48 STC169 (Kar ). That was also a case where liquor was sold in bottles and crates and there was a separate agreement for the sale of contents and the Division Bench upheld the position that the rate of tax as far as the containers were concerned would have to be segregated from the tax that was applicable to the overall turnover in respect of the liquor. Mr. Nazeer has submitted that this decision which was not carried higher and which had not been set aside right up to the date of the amendment held the field and it is therefore his contention that the revisional authority was certainly in error in having interferred with the appellate order. ( 6 ) THE learned Government Advocate submitted that merely because a certain view had been taken in respect of the earlier assessments that it would not ipso facto mean that at a subsequent point of time the assessee would be entitled to identical consideration. We do concede that the factual position particularly in respect of the taxation is material, that it varies from time to time and that if there is a change of circumstances or more importantly, if there has been a change of the legal provisions that the earlier position would certainly not hold good. We do concede that the factual position particularly in respect of the taxation is material, that it varies from time to time and that if there is a change of circumstances or more importantly, if there has been a change of the legal provisions that the earlier position would certainly not hold good. The learned counsel thereafter submitted that the revisional authority was well within his jurisdiction to have interfered with the appellate order because it was his contention that there did not appear to be sufficient material on record factually for purposes of supporting the view that the items which came within the umbrella of the expression "container" had either been separately taxed or that they had been separately accounted for. As far as this latter aspect of the case is concerned, we have relied on two aspects, the first of them being that there are distinct references in the appellate order to the effect that sufficient material was produced before the assessing authority as also before the appellate authority to indicate that a bifurcation had been made and that the records supported this. Secondly, the appellate authority did rely on one other aspect of importance namely the fact that this bifurcation had been accepted in earlier assessments and that the department had not found fault with it but that on the other hand, those orders had assumed finality. Under these circumstances, we see no justification for the conclusions that have been recorded by the revisional authority. ( 7 ) THE law on the point that was applicable for the assessment year in question has virtually been settled by the Division Bench judgment which held the field at the material point of time. Under these circumstances, the revisional order, namely, the impugned order is liable to be set aside and the appellate order stands restored with the clarification however that it shall be confined to the period July 1, 1985 to March 31, 1986. The appellant shall be entitled to the consequential benefits. ( 8 ) THE appeal succeeds to this extent. In the circumstances of the case, there shall be no order as to costs.