JUDGMENT B. Manohar , J.—The appellant being aggrieved by the order dated 2-7-2009 made in KST/SMR/CR-4/2008-09 passed under Section 22A of the Karnataka Sales Tax Act, 1957 by the Commissioner of Commercial Taxes, wherein the Commissioner has set aside the order passed by the Provisional Authority as well as the First Appellate Authority and restored the order passed by the Assessing Authority, has preferred this appeal for the assessment year 2000-01 and 2001-02 The appellant is a Limited Company incorporated under the Companies Act having its registered office at Bombay The Appellant-company registered under the provisions of the Karnataka Sales Tax Act [hereinafter referred to as 'the Act'] is carrying on various types of works contract. The appellant, for the assessment years 2000-01 and 2001-02 had undertaken the works contract from the Bangalore Water Supply and Sewerage Board ('BWSSB' for short) for laying of Clear Water Transmission Mains for supply of water from Knavery Water Supply Scheme, IV Stage. The appellant-company had filed the annual returns of turnover for both the assessment years and paid the tax at 4% on taxable turnover claiming that the pipe laying work falls within Entry 20(ii) of the VI Schedule to the Act. Further, the appellant had claimed certain deductions including the payment to the Sub-Contractors as per the Rules. The returns filed by the appellant for the assessment years 2000-01 and 2001-02 were taken for verification and after verification of the books, the Assessing Authority disallowed certain deductions claimed by the appellant. In addition, the Assessing Authority treated the works executed by the appellant as a composite contract involving two or more of the above categories falling within Entry 44 of the VI Schedule. Further, the Assessing Authority had levied turnover tax under Section 6B of the Act. The Assessing Authority taking into consideration the fact that the assessed is not only laying the pipes but also undertaken some other civil works such as, construction of the pipe bridge over the Suvarnamukhi River, construction of the pedestal supports, anchor block, valve chambers for the pipe line including construction of the causeway across the river with approach road. Accordingly, held that the appellant has carried out composite contract involving two or more works. Accordingly assessed the tax as per the assessment orders dated 10-6-2003 and 10-7-2003 for the assessment years 2000-01 and 2001-02 respectively. 2. Accordingly, held that the appellant has carried out composite contract involving two or more works. Accordingly assessed the tax as per the assessment orders dated 10-6-2003 and 10-7-2003 for the assessment years 2000-01 and 2001-02 respectively. 2. Being aggrieved by the assessment order dated 10-6-2003 and 10-7-2003 for the assessment years 2000-01 and 2001-02, the appellant preferred appeals before the Joint Commissioner of Commercial Taxes (Appeals) (hereinafter referred to as 'the First Appellate Authority') in KSTAP. Nos. 118 & 149/2003-04 contending that works awarded to the appellant by BWSSB is for laying Clear Water Transmission Mains and the steel plates are provided to the appellant by the BWSSB at free of cost and the appellant has fabricated the steel pipe out of the steel plates supplied by the BWSSB and laid steel pipes as water transmission mains. Further excavating work, preparation of the trenches and back filling of trenches and construction of the bridges were only incidental and ancillary to the main contract of laying the Clear Water Transmission Mains. The predominant intention and nature of the contract is to lay the pipeline and it squarely falls within the Entry 20(ii) of the VI Schedule to the Act. The First Appellate Authority by its order dated 12-12-2003 allowed the appeal and held that the works contract carried on by the appellant clearly falls within the Entry 20(ii) of the VI Schedule and directed the Assessing Authority to reconsider the matter afresh. After remand, the Assessing Authority reconsidered the matter keeping in view the direction issued by the First Appellate Authority and by its order dated 12-1-2005 levied the sales tax at 4% on the taxable turnover, treating the works contract carried on by the assessed falls under Entry 20(ii) of the VI Schedule. Further, imposed the tax of 1% on the payment made to the sub-Contractors. Being aggrieved by the order dated 12-1-2005 levying turnover tax at the rate of 1% once again preferred an appeal before the First Appellate Authority in KST. Appeal Nos. 510-511/2004-2005. The First Appellate Authority allowed the appeal by its order dated 30-5-2005 wherein the First Appellate Authority directed the Assessing Authority to levy turnover tax on a portion of the payment made to the subcontractors pertaining to the transfer of the property in goods. 3. Appeal Nos. 510-511/2004-2005. The First Appellate Authority allowed the appeal by its order dated 30-5-2005 wherein the First Appellate Authority directed the Assessing Authority to levy turnover tax on a portion of the payment made to the subcontractors pertaining to the transfer of the property in goods. 3. The Additional Commissioner of Commercial Taxes, feeling aggrieved by the order dated 30-5-2005 and also assessment order dated 12-1-2005 passed by the First Appellate Authority and the Assessing Authority respectively, taken up Suo-motu revision proceedings under Section 22-A(1) of the Act. Notice has been issued to the assessed and the assessed has filed objections to the said revision petition. The Provisional Authority accepted the contentions of the assessed that the works executed by the assessed falls under Entry 20(ii) of the VI Schedule. However, the Provisional Authority restored the assessment order to the extent of levy of turnover tax by its order dated 24-2-2007 for both the assessment years. Thereafter, the appellant filed an application under Section 25A of the Act for rectification of the order dated 24-2-2007 passed by the Provisional Authority. The Provisional Authority considered the said application and passed rectification order on 28-10-2008. Subsequent to the order of the Provisional Authority, the Assessing Authority recomputed the turnover tax on 30-7-2009 for both the assessment years. The Commissioner for Commercial Taxes on verification of the order passed by the Provisional Authority found that the order passed by the Provisional Authority is prejudicial to the interest of the Revenue and issued notice to the appellant under Section 22-A(ii) of the Karnataka Sales Tax Act proposing to set aside the order passed by the First Appellate Authority dated 12-12-2003 as well as the Provisional Authority dated 31-5-2005. The appellant has filed the detailed objections to the said proceedings. The Commissioner for Commercial Taxes after considering the matter, by its order dated 2-7-2009 set aside the order passed by the First Appellate Authority as well as the Provisional Authority thereby restored the orders passed by the Assessing Authority dated 10-6-2003 and 10-7-2003 for the assessment years 2000-01 and 2001-02 and held that works contract undertaken by the appellant falls under Entry 44 of the VI Schedule. The appellant being aggrieved by the order dated 2-7-2009 passed by the Commissioner for Commercial Taxes has preferred this appeal. 4. The appellant being aggrieved by the order dated 2-7-2009 passed by the Commissioner for Commercial Taxes has preferred this appeal. 4. The above appeal has been admitted to consider the following substantial questions of law: i) Whether the Commissioner could have opined that the turnover of the assessed relating to laying of steel pipes in the course of execution of work for M./s. BWSSB and could have brought within the scope of Entry-44 of Schedule-VI to the Karnataka Sales Tax Act, as composite contract or it should have been gone into Entry-20(ii) of the Schedule, as the works contract involving laying of steel pipes other than for either plumbing or drainage facility? ii) Whether suo-motu order dated 2-7-2009 (copy at Annexure-A) passed by the Commissioner in exercise of his revisional power under Section 22A of the Act, was not barred in terms of subsection (3) of Section 23A of the Act, having regard to the fact that the order dated 2-7-2009 where as the assessment orders of reassessment on remand order passed by the Assessing Authority for the period 2000-01 or the order of the Appellate Authority remanding the matter to the original authority for recomputing the liability for this very period in terms of his order dated 12-12-2003 (copy at Annexure-D) are orders without jurisdiction for the reason that it is passed four years beyond the date of order which has sought to be revised.? 5. Smt. Vani, learned counsel appearing for the appellant contended that the order passed by the Commissioner under Section 22-A(ii) of the Act is contrary to law. The revisional power has to be exercised within four years from the date of passing of the order sought to be reviewed. Sub-Section (iii) of Section 22A provides for limitation beyond which, the revisional power cannot be exercised. In the instant case, the Assessing Authority passed the orders on 10-6-2003 and 10-7-2003, the Appellate Authority passed the order dated 12-12-2003, the Additional Commissioner of Commercial Taxes initiated revisional proceedings and passed the order on 30-5-2005. However, the Commissioner initiated revisional proceedings after lapse of four years. Hence, the proceedings initiated by the respondent is barred by limitation. She further contended that the appellant had undertaken the works contract pertaining to providing and laying of steel pipes for the purposes other than sanitary fittings for plumbing, drainage and the like falling within Entry-15. However, the Commissioner initiated revisional proceedings after lapse of four years. Hence, the proceedings initiated by the respondent is barred by limitation. She further contended that the appellant had undertaken the works contract pertaining to providing and laying of steel pipes for the purposes other than sanitary fittings for plumbing, drainage and the like falling within Entry-15. Hence, the work executed by the appellant falls under Entry 20(ii) of the VI Schedule to the Act. The scope of the work includes fabrication of mild steel pipes especially from steel plates supplied by BWSSB to the required diameter and thickness and laying and filling the pipelines from Harohalli to Bangalore City. The said work associated with civil works including construction of the pipe bridge, construction of pedestal supports, anchor block, valve chambers and including construction of the causeway across the river with approach road. Since the pipes are of considerably large size and are heavy, construction of structure involving civil work to give strength to the pipes laid down is more of a necessity than the additional work. These civil works are part and parcel of laying pipe work. In other words, the civil works are the incidental works carried out by the appellant while laying the pipelines. The reasoning of the Commissioner that the work carried by the appellant falls under Entry-44 of the VI Schedule is contrary to law and sought for allowing the appeal. 6. On the other hand Smt. S. Sujatha learned Additional Government Advocate argued in support of the order passed by the Commissioner for Commercial Taxes and contended that as per the works contract, the appellant undertakes the work of not only laying the pipelines, but also fabrication of pipes from the steel supplied by the BWSSB painting and cement mortar lining of pipes fabricated, trenching and excavating pipe route, encasing the pipe with the steel mesh, erection of valves with specials, construction of RCC bridges along the route, construction of pipe saddle support and construction of the overhead tanks. These works cannot be treated as incidental for laying the pipes. The works executed by the appellant is a composite contract involving two or more of the above categories falling under Entry-44 of the VI Schedule to the Act. Hence, the appellant is not entitled for any relief and sought for dismissal of the appeal. 7. These works cannot be treated as incidental for laying the pipes. The works executed by the appellant is a composite contract involving two or more of the above categories falling under Entry-44 of the VI Schedule to the Act. Hence, the appellant is not entitled for any relief and sought for dismissal of the appeal. 7. We have carefully considered the arguments addressed by the learned counsel for the parties and perused the orders passed by the Assessing Authority, Appellate Authority as well as the Provisional Authority. 8. The appellant has entered into works contract with BWSSB for laying Clear Water Transmission Mains from T.K. Halli to Harohalli and Harohalli to Bangalore City from the Knavery Water Supply Scheme, IV Stage. The contract 1.2.2, describes the works contract as under: The scope of work includes fabrication of the pipes and special from the steel plates at Jakkasandra site allotted by the BWSSB. The scope also includes laying, jointing and testing the pipeline from T.K. Halli to Harohalli. The scope also covers the associated civil works including the construction of pipe bridges over Bhima and Arkavathi rivers, construction of the pedestal, ring girder support, anchor blocks and valve chambers of the pipeline. A reinforced concrete overhead tank(one-way surge tank) is to be constructed at J.K. Doddi which is 20 Km from T.K. Halli. The new pipeline is to be laid in the open strip of land acquired, approximately 11 m. width-located on the side of the existing pipeline service road. The major length of the pipeline is proposed to be laid underground. The exposed portion is to be laid above ground supported on the saddles/ring girders on the pipe bridges. The new pipeline is to be laid in the open strip of land acquired, approximately 11 m. width-located on the side of the existing pipeline service road. The major length of the pipeline is proposed to be laid underground. The exposed portion is to be laid above ground supported on the saddles/ring girders on the pipe bridges. The works under this contract shall include but not to be limited to the following: a) Fabrication of 1950 mm dia (clear internal diameter after lining) from mild steel plates supplied by BWSSB free of cost; b) External coating (guniting/epoxy painting) and in-situ internal cement mortar lining; c) Laying jointing and testing of the above fabricated pipe (approximately 44 mm long); d) Fabrication, laying and jointing of pipe specials; e) Procurement and erection of valves; f) Construction of reinforced concrete pipe bridges over Bhima and Arkavathi rivers (Bhima bridge 54 m long and Arkavathi bridge 189 m long); g) Construction of pipe saddle supports, thrust blocks and anchor blocks; h) Construction of one-way surge tank (reinforced concrete overhead tank of 20 m diameter including inlet and outlet connections); i) Construction of valve chambers. 9. The reading of description of the works contract makes it clear that the work carried on by the appellant is a composite contract. It falls under Entry 44 of the VI Schedule to the Act. The contention of the appellant is that the work carried out by the assessed is not a composite contract. It is a single work contract of fabrication of the pipe out of steel plates supplied by the BWSSB and all other works are ancillary to it. The predominant intention and nature of the work is to laying down the pipes. Hence, it falls under Entry 20(ii) of VI Schedule. On careful examination of the works contract awarded by the BWSSB, we are of the view that the contract entered into between the appellant and BWSSB is a composite contract of not only laying of the pipes, but also to do other civil works like construction of the bridges, construction of pipe saddle supports, construction of the valve chambers and RCC over-head tanks, encasing the pipes with the steel mesh, trenching and excavating along the routes. Hence, the works contract entered into by the appellant has to be treated as a composite contract involving two or more of the above categories of works falling under Entry 44 of the VI Schedule. Accordingly, the first substantial question of law is held against the appellant. 10. Insofar as the second substantial question of law is concerned, for the assessment years 2000-01 and 2001-02, the Assessing Authority passed the orders on 10-06-2003 and 10-07-2003. The appeals filed by the appellant were allowed on 12-12-2003. Thereafter, the Assessing Authority passed the fresh order on 12-1-2005. Being aggrieved by the said order, once again appeals were preferred before the First Appellate Authority. Those appeals were disposed of on 30-5-2005. The Provisional Authority took up suo-motu revision for both the assessment years and passed the order on 24-2-2007. Thereafter, the application has been filed under Section 25-A of the Act for rectification of the order dated 24-2-2007. The order was rectified on 28-1-2008. The Commissioner has taken suo-motu revision under Section 22-A(ii) of the Act and order has been passed on 2-7-2009. The appeal order dated 12-12-2003 merged with the revisional order dated 24-2-2007 and the Commissioner has passed the revisional order within a period of four years as required under Section 22-A(iii) of the Act. There is no merit in the contention of the appellant that the revisional order passed by the Commissioner is barred by limitation. Hence, issue No. 2 is also held against the appellant. Accordingly we pass the following: ORDER The appeal is dismissed.