JUDGMENT BILAL NAZKI, J. This is a special appeal against the order of Commissioner of Commercial Taxes. The Appellate Deputy Commissioner, Panjagutta Division, Hyderabad partly allowed, partly remanded and partly dismissed the appeal by an order dated December 30, 1991. The controversy was whether surcharge under section 6-B of the Andhra Pradesh General Sales Tax Act, 1957 has to be included for determining what is the rate of tax on any goods under the APGST Act, 1957 for the purpose of determining the rate of tax under section 8(2) of the Central Sales Tax Act, 1956, i.e., on inter-State sales of non-declared goods not covered by C/D forms. The Appellate Deputy Commissioner followed the judgment of the Sales Tax Appellate Tribunal which was given in case of some appellant in the previous assessment year and held that the surcharge could not be taken into consideration for determining the rate of tax under the APGST Act, 1957 for the purpose of rate of tax under the Central Sales Tax Act, 1956. The Commissioner of Commercial Taxes in revision passed the impugned order revising the order of the Appellate Deputy Commissioner and held that the surcharge has to be taken into consideration for determining the rate of tax under the APGST Act for the purpose of determining the rate of tax under section 8(2) of the Central Sales Tax Act, 1956. Now the question which has been raised for decision of the High Court mainly relates to interpretation of section 20(2-A) of the A.P. General Sales Tax Act, 1957. Eight questions have been framed as substantial questions of law in para (ii) of the memorandum of appeal. Of them, six questions relate to interpretation of section 20(2-A) of the A.P. General Sales Tax Act, 1957. Another question is whether the surcharge can be levied under section 8(2) of the Central Sales Tax Act, 1956. Third question relates to whether the revisional order of the Commissioner was barred by limitation, but this was not argued. Now coming to the first question as to what is the scope of section. Another question is whether the surcharge can be levied under section 8(2) of the Central Sales Tax Act, 1956. Third question relates to whether the revisional order of the Commissioner was barred by limitation, but this was not argued. Now coming to the first question as to what is the scope of section. 20(2-A) of the A.P. General Sales Tax Act, 1957, which lays down, "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." It is contended that this section is in the nature of res judicata, confining to the case which has been directly decided by the Tribunal, but the Tribunal's judgment has not any precedential value. Suppose a question is decided by the Tribunal in an assessment year, it is not binding in any other cases for the authorities. The learned counsel for the respondent submits that once a particular issue in a particular assessment year has been decided by the Tribunal, that cannot be reopened by the authorities, but if a similar question has to be decided in some other proceedings for a different assessment year, the judgment of the Tribunal will have no value because the judgment of the Tribunal does not become a precedent to be followed. The learned counsel for the appellant, on the other hand, submits that once the same question has been decided between the parties by the Income-tax Tribunal which is a higher authority for a particular assessment year, it would not be competent for the sales tax authorities to decide the issue in a subsequent assessment year contrary to the judgment of the Tribunal. The learned Commissioner has held that since the rules of res judicata do not operate in case of tax matters, therefore the judgment of the Tribunal in a previous year was not binding on him. Reference is made to judgment of a Full Bench of this Court reported in State of Andhra v. Arisetty Sriramulu [1957] 8 STC 153 in which it was held, ".......... Reference is made to judgment of a Full Bench of this Court reported in State of Andhra v. Arisetty Sriramulu [1957] 8 STC 153 in which it was held, ".......... 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." Similarly the Supreme Court in a judgment reported in Instalment Supply (Private) Ltd. v. Union of India [1961] 12 STC 489 held, "It is well-settled that in matters of taxation 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." Section 20(2-A) of the APGST Act, 1957 also caught the attention of this Court in Minerals and Metals Trading Corporation of India Limited v. Deputy Commissioner Commercial Taxes, Vishakapatnam [1978] 42 STC 372 and it held : "......... Section 20(2-A) of the APGST 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." Thus in view of these judgments, we do not think that the learned Commissioner was wrong in holding that he was not bound by the Tribunal passed in an earlier assessment year. The learned counsel for the appellant has, however, referred to judgment of this Court reported in State of Andhra Pradesh v. Toshiba Anand Batteries Ltd. [1995] 96 STC 664. This judgment does not throw much light on the controversy on hand as it basically considered the question of limitation for exercise of revisional powers by the authorities. Now coming to the question whether surcharge under section 6-B of the APGST Act, 1957 has to be included for determining the rate of tax under section 8(2) of the Central Sales Tax Act, 1956 section 6-B of the APGST Act, 1957 provides that every dealer, who is liable to pay tax under this Act on the sale or purchase of goods shall pay a surcharge on such tax at the rate of 10 per cent of such tax. Section 8(2)(b) of the Central Sales Tax Act, 1956 lays down the rate which is applicable to sale or purchase of such goods inside the appropriate State. The contention of the learned counsel for the appellant is that under section 8(2)(b) of the Central Sales Tax Act the rate applicable with regard to sales tax would not include surcharge payable under the State Act. On the other hand, the learned counsel for the respondent submits that this question has already been decided by a division Bench of this Court in Sree Satyanarayana Spinning Mills Ltd. v. Commercial Tax Officer [1988] 68 STC 95; (1987) 5 APSTJ 142 and it held, "................ we are of the opinion that when sub-section (2-A) of section 8 of the Central Sales Tax Act speaks of the lower rate at which sales tax is charged under the State enactment, it includes not only the sales tax chargeable under section 5 and additional sales tax chargeable under section 5-A, but also surcharge leviable under section 6-B of the State enactment. In other words, whatever is payable by way of tax under the State enactment in the case of intra-State sale, will also be payable by way of Central sales tax in the case of inter-State sale, in cases to which sub-section (2-A) will apply." The learned counsel for the appellant has, however, drawn our attention to the judgment of the Supreme Court reported in Deputy Commissioner of Sales Tax v. Aysha Hosiery Factory (P.) Ltd. [1992] 85 STC 106, but we do not consider that this judgment is in any way contrary to the judgment of the division Bench of this Court. The Supreme Court, while considering whether the additional sales tax was required or not for the purpose of section 8(2) of the Central Sales Tax Act, 1956, held : "The question for consideration is as to whether the additional tax levied under the Kerala Additional Sales Tax Act is also to be considered as sales tax under the 'sales tax law' of the State. The question could not have arisen but for the fact that this additional levy came to be imposed under a separate Act. Had the additional sales tax been imposed by simply amending the rates in the original Act, the question would not have arisen. But we are of the view that this makes no difference and it is merely a matter of style of legislation. The additional sales tax levied under the Additional Sales Tax Act is also sales tax of the same category as in the original Act. The Kerala Additional Sales Tax Act provides that 'The tax payable under Kerala General Sales Tax Act, 1963 (15 of 1963) (hereinafter referred to as 'the State Act') for every financial year commencing from the financial year 1978-79 shall be increased by 10 per cent of such tax'. Instead of increasing the rate of tax for each of the commodities which are covered by the Kerala General Sales Tax Act by one comprehensive provision, the tax is increased by 10 per cent over the rate provided under the original Act in respect of all the commodities the sale or purchase of which are taxable. Both take the form of sales tax and in the case of assessment of local sales it makes no difference whether it is called tax and additional tax or one higher percentage of tax. Both take the form of sales tax and in the case of assessment of local sales it makes no difference whether it is called tax and additional tax or one higher percentage of tax. In truth and effect it is a levy of tax on the sales or purchases of the dealers." The learned counsel for the appellant has, however, referred to a judgment of this Court reported in India Fruits Private Limited, Kadiam v. Commercial Tax Officer [1988] 68 STC 114. This judgment has been given altogether in a different context. The question was not whether the surcharge leviable under section 6-B of the APGST Act, 1957 could be included in tax, but the question related to some G.O. and the G.O. was under attack before the court. For the reasons given herein above, the appeal it dismissed. No costs. Appeal dismissed.