JUDGMENT C. N. Ramachandran Nair, J. Heard the learned senior counsel Dr. K. B. Mohammed Kutty appearing for the Petitioner and the learned Government Pleader. A common question arises for consideration in all these three Tax Revision Cases filed by the petitioner who was engaged in the purchase of coconut/copra for manufacture of desiccated coconut powder for Inter-State sale. The Assessing Officer while completing the assessments for 1993-94 to 1995-96 granted exemption on purchase turn over of coconut/copra under Notification SRO No. 1729 of 1993 which was amended by notification SRO No. 404 of 1994. Petitioner was also granted exemption on sales turn over of desiccated coconut powder under another Notification. The assessments were subject-matter of appeals. Original assessments were set aside by the Appellate Authority by the common order dated 28.4.1999. The Assessing Officer thereafter revised the assessments on 10.4.2000. These orders were revise by the Deputy Commissioner under Section 35 of the KGST Act for withdrawing the exemption on purchase turnover of coconut and copra wrongly granted to the petitioner by the Assessing Officer. Even though the petitioner raised objection against the suo motu revisional proceedings, the Deputy Commissioner overruled the same and passed orders. Appeals filed against the said orders were unsuccessful and hence these revisions are filed. The first contention raised is that the orders of the Deputy Commissioner are beyond the time limit of 4 years provided under Section 35(1) of the Act. The contention of the counsel is that the period of limitation should be reckoned with reference to the date of original assessment and if that is done, the suo motu revisional proceedings issued by the Deputy Commissioner are time barred. Learned Government Pleader, on the other hand, contended that the time limit has to be reckoned from the date of the revised assessments which is the order revised by the Deputy Commissioner under Section 35 of the Act. The question to be considered, therefore, is whether the Deputy Commissioner could have initiated proceedings under Section 35 of the Act in respect of a matter which was decided by the Assessing Officer in the original assessment itself. In fact the exemption on the purchase turn over of coconut/copra was granted in the original assessments and the said issue was not subject-matter of appeal. In fact the exemption on the purchase turn over of coconut/copra was granted in the original assessments and the said issue was not subject-matter of appeal. However, since the Appellate Authority set aside the original assessments, the findings with regard to the exemption on coconut/copra was incorporated again in the revised order by the Officer. Even though exemption on purchase turnover was granted in the original assessments, the Deputy commissioner could not have invoked jurisdiction under Section 35 of the Act because original assessments did not survive as the Appellate Authority set aside the original orders. Therefore, we are of the view that the Deputy Commissioner rightly invoked the suo motu revisional jurisdiction against the revised assessments completed on 10.4.2000. It is admitted that if limitation is reckoned from the date of revised assessments, the orders are within time. In the circumstances and since the original assessments were set aside by the Appellate Authority, we hold that the suo motu revisional jurisdiction was rightly exercised by the Deputy Commissioner against the revised assessments and the order so passed is within the time prescribed under Section 35(1) of the Act. So far as the merits of the case is concerned, the Notification above referred provided for exemption for purchase tax on coconut/copra only if inter-State sale of the same suffers tax under the CST. However, it is admitted that CST assessments were completed without levying tax on desiccated coconut powder because of the exemption available for the petitioner under the Notification. Therefore, the petitioner was rightly ineligible for exemption on purchase turn over of coconut/copra. Hence, this issue is also found against the petitioner. Counsel for the petitioner pointed out hardships caused to the petitioner on account of the undue delay in completing the proceedings by the statutory authorities. He has also pointed out that but for the unsolicited setting aside of the assessments by the Appellate Authority, the suo motu revisional orders would not have been saved by limitation. In the circumstances and on account of the delay in completion of the proceedings and the pendency of the revision cases before this Court, we think that the petitioner can be granted full waiver of interest and also installment facility can be granted for clearing the arrears of sales tax due under the Act for the assessment years 1993-94 to 1995-96. We accordingly waive the complete interest payable under Section 23(3) of the Act, provided petitioner clears the arrears of tax in three equal monthly installments. The first installment shall be made on or before 31.12.2006 and the balance installments shall be made on or before the last day of the two succeeding months. Counsel for the petitioner submitted that refund is due to the petitioner for the years 1991-92 to 1994-95. If any amount is already paid or any refund is due to the petitioner, the same will be verified and adjusted and the Officer concerned should give statement to the petitioner showing the payment already made, refund adjusted and balance due from the petitioner. The Assessing Officer shall furnish statement to the petitioner immediately on production of a copy of this judgment by the petitioner. Petitioner will make payment and settle the liability as above on receipt of the statement. Sales Tax Revision Cases are disposed of as above.