JUDGMENT B. Prakash Rao, J. The appellant herein, who is a manufacturer of liquor, files this appeal under section 23(1) of the Andhra Pradesh General Sales Tax Act, 1957 (for short, "the Act") assailing the orders of the Commissioner of Commercial Taxes, Hyderabad, dated July 20, 1996 purported to have passed in exercise of powers of revision under section 20(1) of the said Act. The facts, as necessary for disposal of the present appeal are that in the course of its business as a manufacturer of liquor under D2 licence granted under the provisions of the A.P. Excise Act, 1968, the appellant had to sell the liquor in various containers, viz., bottles, cartons and other packing material. The main dispute is in regard to levy of tax on the containers. According to the appellant, it had followed the principles as laid down by the Supreme Court in Raj Sheel v. State of Andhra Pradesh [1989] 74 STC 379, and accordingly, the Appellate Deputy Commissioner by his order dated July 17, 1992 held that there was separate sale of packing material and the norms were satisfied and remanded the matter to the assessing authority, and consequently assessment order was passed on October 23, 1992. By this, orders are sought to be revised by the Commissioner under section 20 of the said Act on the ground that there is no such distinction in both the transactions. Accordingly, as contemplated under sub-section (2) of section 20 of the said Act, a show-cause notice was issued on July 6, 1996, which was served on the appellant on the same day. The appellant had filed objections and a personal hearing was given on July 20, 1996 by issuing a notice dated July 17, 1996, which was served on the same day of issuance. Thereupon, the orders are passed on the same day, i.e., on July 20, 1996 setting aside the orders of the appellate authority dated July 17, 1992 and the consequential orders passed by the assessing authority on October 23, 1992 restoring the original assessment order dated June 9, 1989. It is these proceedings, which are under challenge in this appeal. Thereupon, the orders are passed on the same day, i.e., on July 20, 1996 setting aside the orders of the appellate authority dated July 17, 1992 and the consequential orders passed by the assessing authority on October 23, 1992 restoring the original assessment order dated June 9, 1989. It is these proceedings, which are under challenge in this appeal. The main submission made on behalf of the appellant apart from the merits is that under section 20 of the said Act, the period of limitation prescribed for any exercise of powers is four years, and therefore, the impugned action is at the fag end and is wholly unsustainable, especially, when there being no such order served on the appellant within the said prescribed period, and the entire action is liable to be set aside. The learned Special Government Pleader appearing on behalf of the respondent sought to sustain the impugned action on the ground that the Commissioner had issued show-cause notice well within the time and orders are passed and therefore there is no illegality. On this and other submissions made, the point, which arises for consideration, is whether in the facts and circumstances, the exercise of powers under section 20 of the A.P. General Sales Tax Act, 1957 is sustainable. Since the plea of "barred by limitation" is being taken up for consideration, we are not going into the merits of the case. Therefore, it would suffice to note that admittedly in this case, the order of the appellate authority is dated July 17, 1992 and the consequential orders were passed by the assessing authority on October 23, 1992. Therefore, the period of limitation of four years had to be reckoned from the date of the appellate authority order. There is also no dispute to the fact that the authorities constituted under the aforesaid Act in its hierarchy, both at the stage of assessment and in appeal, have considered on merits and ultimately passed the orders. In terms of the said order in appeal dated July 17, 1992, the fresh order was passed by the assessing authority on October 23, 1992. In terms of the said order in appeal dated July 17, 1992, the fresh order was passed by the assessing authority on October 23, 1992. During the course of hearing on behalf of the respondents herein, a detailed counter-affidavit was filed sworn to by Sri D. Ramachandra Reddy, the Joint Commissioner (CT), Enforcement Wing, who in para 5 submitted specifically that the said show-cause notice was issued on July 6, 1996 and was served on the same day. Subsequently, another notice was issued on July 17, 1996 for a personal hearing on July 20, 1996 and on the same day the orders were passed. Further, in the said affidavit, it is stated that this order, which was passed on July 20, 1996 was sent for service to the appellant through the assessing authority on September 24, 1996, and the same was served on January 28, 1997. It is this later action on the part of the revisional authority, which is being assailed. For convenience sake, the powers as conferred under section 20 contemplating exercise of suo motu powers by the Commissioner on being satisfied that it would be prejudicial, especially, to the interest of Revenue, is extracted here under, which reads as follows : "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, he 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) 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. (2A) 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. (3) In relation to an order of assessment passed under this Act, the powers conferred by sub-sections (1) and (2) shall be exercisable only within such period not exceeding four years from the date on which the order was served on the dealer, as may be prescribed. (4) No order shall be passed under sub-section (1) or sub-section (2) enhancing any assessment unless an opportunity has been given to the assessee to show cause against the proposed enhancement. (5) Where an order passed under this section has been set aside by any court or other competent authority under this Act for any reason the period between the date of such order and the date on which it has been so set aside shall be excluded in computing the period of four years specified in sub-section (3) for the purpose of making a fresh revision, if any, under this section. (6) Where any proceeding under this section has been deferred on account of any stay order granted by the Special Appellate Tribunal in any case, or by reason of the fact that an appeal or other proceeding is pending before the Special Appellate Tribunal or the Supreme Court involving a question of law having a direct bearing on the order or proceeding in question, the period during which the stay order was in force or such appeal or proceeding was pending shall be excluded in computing the period of four years specified in this section for the purpose of exercising the power under this section." Apparently, the aforesaid provision is virtually the powers, specifically, conferred on the Commissioner of Commercial Taxes to revise any proceedings or orders. De hors the fact that it has undergone the natural course through the assessing authorities and as well as by the appellate authorities, this power is a special power, which is not in the format of hierarchical remedies, provided under the said Act. The period of limitation prescribes that there is four years time from the date the order was served on the party. Therefore, such power, which is almost akin to that of an extraordinary one in exceptional circumstances should be exercised within the reasonable period and before the expiry of the time prescribed thereunder. However, in this case, it is seen that even though the appellate authority has passed the orders on July 17, 1992, the show-cause notice came to be issued on July 6, 1996. There is absolutely no explanation forthcoming as to how such exercise is being made and on what basis. This was followed by providing a personal hearing by giving a notice on July 17, 1996, which is served on the same day. Even the earlier show-cause notice dated July 6, 1996 was served on the same day. The objections were filed by the appellant and the order passed in pursuance of the show-cause notice is on the same day of personal hearing, i.e., on July 20, 1996. These orders stated to have been sent for service to the appellant on September 24, 1996 with a two-month gap, and the same was served on the appellant on January 28, 1997, which is almost a four-month gap. The fact that the show-cause notice and personal hearing were given at the fag end of the expiry of the period of four years may not be much in dispute, but, however the orders passed on July 20, 1996 give rise to several doubts, especially, when it has taken two months for the parties to send the said orders to be served on the appellant and for actual service to be effected four months thereafter. When in all such hurriedness show-cause notice and the personal-hearing notice can be served on the same day, why have the parties taken such a leisure manner to take steps to serve the orders ? Therefore, it does not create any confidence that the order could have been passed on the same day in which it was stated to be passed. Therefore, it does not create any confidence that the order could have been passed on the same day in which it was stated to be passed. Therefore, we are of the view that the very action on the part of the revisional authority in disposing the matter in such a late hour is wholly misconceived and unsustainable. The appeal is accordingly allowed and the impugned order dated July 20, 1996 in CCT's Ref. No. L. III(1)/504/A/93 passed by the Commissioner of Commercial Taxes, Hyderabad is set aside. No costs.