Judgment : Maniula Chellur, C.J. 1. This revision petition is directed against the order of the Appellate Tribunal dated 30.05.2013. The brief facts that led to filing of this revision are as under: Revision petitioner is running M/s.Al Ahali Business Trade Link (P) Ltd., a registered dealer in jewellery of gold, silver and platinum group of metals with the brand name Malabar Gold at City Centre, Thrissur. Revision Petitioner shifted its business premises to Sankara Iyer Junction, M.G.Road, Thrissur after intimating assessing authority as per letter dated 25.06.2010. He filed an application for payment of tax at compounding rate for the year 2010-11 during which period the business premises was shifted. This came to be accepted. However, when an application came to be filed for payment of tax at compounding rate for the year 2011-12, same was rejected stating that business premises was shifted. Revision petitioner contends, it is not a sufficient reason for rejecting the application for composition under Section 8(f)(ii) of the Kerala Value Added Tax Act, 2003 (for short 'the Act'). Aggrieved by the same, assessee filed an appeal before the Appellate Tribunal, which came to be dismissed, against the same, present revision is preferred. 2. Revision petitioner raised following grounds upon which he seeks to set aside the order of the respondent authority; the order refusing the application is beyond show cause notice; change of business premises during the year 2010-11, which was approved, cannot be a ground for rejecting the application; prior approval of the District Deputy Commissioner as required under the statute was not obtained; shifting of business premises per se cannot be a ground to reject the application unless it is for valid reasons; there was no reason to reject the compounding application for the year 2011-12 when such compounding was permitted for 2010-11. Questions of law raised for decision by this Court are as under: "a. Ought not the Tribunal should have found that the shifting of business premises per se is not sufficient reason unless it is supported by objective reasons and in the case on hand there are no such objective reasons so as to justify the rejection of the application for compounding? b. Having observed that the discretion sought to be exercised by the assessing authority in all respects shall be proper and reasonable and guided by judicial principles, has not the Tribunal committed an error in law by holding that the words contained in the section 8(f) (ii) of the Kerala Value Added Tax Act 2003 granting power to reject the application for composition is, not discretionary? c. Having no dispute, that the shifting of the business premises was done during the year 2010-11 which was duly communicated and acknowledged by the assessing authority, has not the Tribunal failed to decide whether the assessing authority is justified in rejecting the application for composition under 8(f) of the Kerala Value Added Tax Act 2003 for the year 2011-12(next year) when this issue was specifically raised before the Tribunal ? d. Having complied with the requirements of section 8(f) (v) (d) of the Kerala Value Added Tax Act 2003 by paying tax as provided therein during the year *2011-12, has not the Tribunal committed an error in law by holding that the rejection of the compounding facility for the year 2011-12 under Section 8 (f) (ii) of the Kerala Value Added Tax Act 2003, is in order ? (* year is changed as per order in LA.No.2578/2013 in O.T.Rev.No.l 10/13) e. Ought not the Tribunal should have interfered in the Order of the assessing authority as per Annexure A5, when the Notice or the Order as per Annexure A3 and A5 issued by the assessing authority does not refer anything about the mandatory requirement of prior approval of District Deputy Commissioner as provided under proviso clause to section 8(f)(ii) of the Kerala Value Added Tax Act 2003? f. Ought not the Tribunal should have found that the District Deputy Commissioner should have granted opportunity of being heard and for filing objections to the Revision Petitioner before granting approval to the assessing authority to reject the application for composition, if at all any such approval has been granted? f. Ought not the Tribunal should have found that the District Deputy Commissioner should have granted opportunity of being heard and for filing objections to the Revision Petitioner before granting approval to the assessing authority to reject the application for composition, if at all any such approval has been granted? g. Having alleged in the Notice in Annexure A3 that the Revision Petitioner has not intimated the opening of the business place at Sankara Iyer Road, whereas in the Order in Annexure A5, it was found that opening of the business place at Sankara Iyer Road was duly informed, ought not the Tribunal should have found that the reasons stated in the Annexure A3 Notice for rejection of the application for composition is not what is relied upon in the Annexure A5 Order?" 3. As against this, learned Government Pleader placed his arguments on the following lines: The option exercised by the assessee for compounding under Section 8(v) of the Act for the year 2010-11 was permitted by an order dated 31.05.2010. The assessee shifted his place of business from City Centre, Thrissur to Sankara Iyer Junction, M.G.Road, Thrissur with effect from 01.07.2010. Therefore, the assessing authority rejected the application for compounding for the year 201112 relying on sub-section (ii) of Section 8(f) of the Act only after hearing the assessee. The said provision contains several reasons upon which the concerned authority can refuse permission for compounding, which includes shifting of place of business as well. The Tribunal considered all the relevant facts while dismissing the appeal. Since the scope of tax revision is very limited, assessee cannot assail conclusion arrived at on the basis of factual issue in the absence of perversity or arbitrariness in the said order. The challenge so far as validity of the provision is beyond the scope of tax revision, therefore, revision petition cannot be entertained. According to Revenue, compounding being an option, it is wholly within the choice and pleasure of the dealer. No compulsion to opt exists. It is hassle free method of taxation as against the regular assessment. The dealer who is aware of the scheme of compounding cannot doubt the same. Subsequently, it is not correct on the part of assessee to complain about any of the conditions or restrictions imposed in the scheme or provision. No compulsion to opt exists. It is hassle free method of taxation as against the regular assessment. The dealer who is aware of the scheme of compounding cannot doubt the same. Subsequently, it is not correct on the part of assessee to complain about any of the conditions or restrictions imposed in the scheme or provision. If it is not beneficial, no one can compel him to opt the same, therefore, revision petitioner has to blame itself for the situation in which it is now placed. 4. Learned counsel for revision petitioner relies upon AIR 1965 SC 1325 in the case of Chittoori Subbanna v. Kudappa Subbanna and others to contend that pure question of law if not depending on facts can be raised as a new plea. He also relies upon Commissioner of Sales Tax, Madhya Pradesh, Indore and others v. Radhakrishnan and others ( (1979) 2 SCC 249 ) regarding presumption of constitutionality. He further contends, while considering the validity of a statute, presumption is always in favour of its constitutionality and the burden is upon the person who attacks it to show that there has been a clear transgression of constitutional principles. He further contends that it must always be presumed that Legislature understands and correctly appreciates the need of its own people and that discrimination, if any, is based on adequate grounds. Courts will be justified in giving a liberal interpretation to the section in order to avoid constitutional invalidity. These principles have given rise to the rule of reading down the sections if it becomes necessary to uphold the validity of the sections. 5. He further relies upon ( (2001) 1 SCC 460 ) in the case of K.Govindan and Sons v. CIT, Cochin again to stress upon the principle that interpretation that leads to absurdity must be avoided. 6. Learned Government Pleader relies upon several decisions in support of his contentions. 1980 Supp SCC 229 in the case of State of Maharashtra and others v. Shri V.S.Naik is relied upon, which pertains to service matter and the controversy that arose was, whether the impugned notice cum order of compulsory premature retirement from service passed against the respondent was in strict compliance with Rule 8, note (1) of the Revised Pensions Rules 1950. The said Rule required to record the exact reasoning in writing in each case. The said Rule required to record the exact reasoning in writing in each case. It was held that reason may be recorded in the concerned file and need not be mentioned in retirement order. The expression 'such as' in the said Rule indicates, grounds are only illustrative and there can be other grounds also. It is contended that Rule 8 (f)(ii) indicates certain instances only where registration could be rejected or withdrawn, therefore the reasons mentioned thereunder are only illustrative and not exhaustive. 7. (1997) 104 STC 134 (SC) in the case of State of Kerala and another v. Builders Association of India and others is relied upon. The question that arose in the said case was whether provisions of Kerala General Sales Tax Act, i.e., Sections 5(l)(iv), 7(7), (7-A), (11) and (12) were beyond the legislative competence of State Legislature. In that context, their Lordships, by referring to R.K.Garg v. Union of India ((1982) 133 ITR 239 (SC)) opined that object of sub-sections (7) and (7A) is the same as that of Section 5(l)(iv). It is only a different route to arrive at the same destination. Their Lordships further opined that every legislation particularly in economic matters is essentially empiric and it is based on experimentation or what one may call trial and error method and therefore, it cannot provide for all possible situations or anticipate all possible abuses. There may be crudities and inequities in complicated experimental economic legislation but on that account alone it cannot be struck down as invalid. 8. He refers to the decision M/s.Mycon Construction Ltd. v. State of Karnataka and another ((2002) 10 KTR 452 (SC)) wherein constitutional validity of the method of tax, composition of tax in lieu of regular assessment under Section 5B, providing an enhanced composition fee with retrospective effect from 01.04.1988, was the subject matter. It was held that State Legislature is competent to enact such a provision. There is no compulsion for the assessee to opt for the composition scheme, hence no prejudice is caused in any manner whatsoever. Challenge to the provisions as constitutionally invalid was repelled. 9. The decision in State of Tamil Nadu v. M.K.Kandaswami and others ( 1975 36 STC 191 ) is relied upon to contend that while comparing Section 5A of Kerala General Sales Tax Act, their Lordships had an occasion to deal with Section 7A of Madras General Sales Tax Act. Challenge to the provisions as constitutionally invalid was repelled. 9. The decision in State of Tamil Nadu v. M.K.Kandaswami and others ( 1975 36 STC 191 ) is relied upon to contend that while comparing Section 5A of Kerala General Sales Tax Act, their Lordships had an occasion to deal with Section 7A of Madras General Sales Tax Act. Section 7A of Madras General Sales Tax Act was challenged, questioning the competency of State Legislature to impose tax on the use and consumption of goods, therefore said section was ineffective. While referring to the judgment of the Kerala High Court in Yusuf Shabeer v. State of Kerala ( (1973) 32 STC 359 ), their Lordships opined that goods, the sale or purchase of which is liable to tax under the Act in Section 7A(1) means, taxable goods, that is, the kind of goods, the sale of which by a particular person or dealer may not be taxable in the hands of the seller but the purchase of the same by a dealer in the course of his business may subsequently become taxable. It was further held that Section 7A itself is a charging section and creates a liability against a dealer on his purchase turnover with regard to goods, the sale or purchase of which though generally liable to tax under the Act, have not, due to the circumstances of particular sales, suffered tax under Section 3, 4 or 5, and which after the purchase have been dealt with by him in any of the modes indicated in clauses (a), (b) and (c) of Section 7A(1). 10. He relies upon the decision Commissioner of Sales Tax, U.P. v. Kumaon Tractors & Motors ( (2002) 9 SCC 379 ), in which it was held that under Section 11 of U.P.Trade Tax Act, 1948, the jurisdiction of a High Court was only to interfere with the Tribunal's order and the scope is a limited jurisdiction to interfere on the question of law which has to be precisely stated or formulated. Therefore, the order of the High Court was set aside opining that High Court re-appreciated the evidence and ignored the material documents and held that assessee was not a dealer but was entitled to receive commission. Therefore, the order of the High Court was set aside opining that High Court re-appreciated the evidence and ignored the material documents and held that assessee was not a dealer but was entitled to receive commission. He also relies upon (2010) 18 KTR 420 (SC) in the case of Commissioner of Trade Tax, U.P. v. J.U. Pesticides & Chemical (P) Ltd. to stress upon the fact that while exercising the re visional power, court has limited jurisdiction to interfere with the orders of the Tribunal and interference can only be on the question of law which has to be precisely stated and formulated. Interference with the orders of the Tribunal on factual aspects is not proper, therefore it is to be set aside. 11. Stand of revenue is, the object of Section 8(f) of the Act is to provide an alternate scheme of taxation without sacrificing the interest of the Revenue. While computing the compounding tax, annual tax and the tax paid/payable for previous year has much relevance. Therefore, place of business is a crucial aspect which goes to the root of method of taxation and the restriction contained in sub-section (ii) of Section 8(f) is in consonance with the object and purpose of the scheme. Even otherwise, it is a matter of common knowledge that place of business is a relevant factor in order to avoid any scrupulous dealer taking advantage of the situation by opting for compounding based on the turnover and the tax paid for previous year for a shop situated in the suburbs of city and subsequently, shifting the place of business to the heart of the city. One of the grounds introduced was shifting the place of business. Therefore, shifting of place of business itself is a sufficient ground to refuse permission for compounding. Approval of higher authorities is only an administrative check on the assessing authorities. Same was received before issuance of the order to the assessee. No material was produced by the dealer before the fact finding authority that shifting of business premises has not resulted in substantial increase in the turnover. During the year 2010-11, the assessee conducted business in the old building for three months and thereafter for nine months in the new building. Hence, the sales tax turnover comparison has to be done month wise during 2010-11 and 2011-12. 12. During the year 2010-11, the assessee conducted business in the old building for three months and thereafter for nine months in the new building. Hence, the sales tax turnover comparison has to be done month wise during 2010-11 and 2011-12. 12. In order to understand the real question of controversy, it would be apt to refer to the statutory provision, i.e., Section 8(f) of the Act, which reads as under: "8. Payment of tax at compounded rates.- Notwithstanding anything contained in Section 6, - xxxxxxxxxx (f)(i) any dealer in ornaments or wares or articles of gold, silver or platinum group metals including diamond may at his option, instead of paying tax in respect of such goods in accordance with the provisions of section 6, pay tax at, - (a) one hundred and fifteen per cent, in case their annual turnover for the above goods for the preceding year was rupees ten lakhs or below; (b) one hundred and twenty per cent, in case their annual turnover for the above goods for the preceding year was above rupees ten lakhs and up to rupees forty lakhs; (c) one hundred and thirty five per cent, in case their annual turnover for the above goods for the preceding year was above rupees forty lakhs and up to rupees one crore; and at (d) one hundred and fifty per cent, in case their annual turnover for the above goods for the preceding year exceeded rupees one crore; of the highest tax payable by him as conceded in the return or accounts, or tax paid by him under this Act, whichever is higher, for a year during any of the three consecutive years preceding that to which such option relates. xxxxxxxxxx (ii) The assessing authority, for valid and sufficient reasons, such as shifting of place of business, furnishing of false information, suppression of relevant information, failure to furnish such information demanded, may refuse permission to pay tax under this section and cancel the permission if any granted: Provided that no orders under this sub-clause shall be issued without giving the dealer an opportunity of being heard and without prior approval of the District Deputy Commissioner." Reading of the above provisions clearly indicate, there could be several valid and sufficient reasons upon which the assessing authority may refuse permission to pay tax under the above section and can even cancel the permission if already granted. Some of the reasons are enumerated under sub-section (ii) of Section 8(f), i.e., shifting of place of business, furnishing of false information, etc. The reasons enumerated in the provision are only illustrative and not exhaustive. There may be instances where the reasons could be altogether different from what is enumerated under sub-section (ii). Section 8(f)(i) provides option for a dealer in ornaments or articles of gold, silver, platinum group metals to pay tax at compounding rate instead of paying tax in accordance with the provisions of Section 6. No doubt, this is a benefit or concession given to the dealer to opt a method under which he intends or desires to pay tax depending upon the turnover. By this method, no doubt, interest of Revenue is also protected. However, in the present case, one has to see whether there is strict compliance of the provision by the authority while considering the application of the dealer for compounding rate of tax for the year 2011-12 and whether authority concerned did exercise its power in accordance with the provisions contemplated. 13. So far as proviso to Section 8(f)(ii), according to revision petitioner, there is nothing on record to show that there was prior approval of the District Deputy Commissioner before rejecting the application of the dealer seeking permission for payment of tax at compounding rate. According to revision petitioner, there was no application of mind on the part of the competent authority before it rejected the application of the dealer. This must be evident from the facts borne on record. Therefore, on perusal of the show cause notice at Annexure-A3 and the proceedings at Annexure-A5 rejecting the claim of the dealer for compounding, it clearly indicate that there was no application of mind by the competent authority. Annexure- A3 reads as under: "Take notice that you have filed return in form 10 for the month of April 2011 opting to pay tax at 125% of the average monthly tax paid during the last financial year (10-11). It may be noted that during the last financial year, after opting for compounding you have shifted your place of business from City Centre, Thrissur to Shankara Iyer Road, Thrissur. But you have not changed the address of your business place, and have not intimated the opening of branch business place at Shankara Iyer Road. It may be noted that during the last financial year, after opting for compounding you have shifted your place of business from City Centre, Thrissur to Shankara Iyer Road, Thrissur. But you have not changed the address of your business place, and have not intimated the opening of branch business place at Shankara Iyer Road. It is therefore proposed to reject the claim for compounding at 125% of the compounded tax paid during 10-11 under Section 8(f)II of the Act. Your objection to the proposal, if any, should be filed within 7 days of receipt of this notice. You are also given an opportunity of being heard." Annexure-A5 reads as under: "M/s.Al-Ahali Business Trade Links (P) Ltd., is an assess on the rolls of this office doing business in jewellery of gold, silver & platinum group of metals with the branch name Malabar Gold at Door No.19/441/1-2, Sankara Iyer Junction, MG Road, Thrissur. The dealer had opted and paid tax @ ? 8,28,083.00 per mensum including cess under section 8(f)(v) for the year 2010-2011 as per the proceedings issued from this office No.TIN 32080262152 dt. 31.05.2010 at Door No.XXV/1130/1 at City Centre, Round West. But from 01.07.2010 the dealer had shifted their place of business from Door No. XXV/1130/1 to City Centre, Round West to Door No. 19/441/1 &2 -Sankara Iyer Junction, MG Road, Thrissur. As per section 8(f)(ii) the assessing authority for valid and sufficient reason such as shifting of place of business holding of stock exceeding double the quantity held in the previous year, furnishing of falls information suppression of relevant information, failure to furnish such information demanded may refuse permission to pay tax under this section and cancel the permission if any granted. In view of the above provision a notice dt.24.05.2011 was served on the assess stating that they are not eligible to pay tax @ 125% of the tax paid during the previous year under section 8(f)(v) of the Act as they have shifted their place of business during the year 2010-2011 after obtaining the compounded proceedings at the old business place in Door No.XXV/1130/1, City Centre, Round West. In reply to the notice they have stated that the business place was shifted w.e.f. 01.07.2010 from City Centre to Sankara Iyer Road, and the fact has been communicated to the assessing authority sufficiently early as per their Lr.No.M/TCR/2010-2011 dt.25.06.2010 under proper acknowledgment. In reply to the notice they have stated that the business place was shifted w.e.f. 01.07.2010 from City Centre to Sankara Iyer Road, and the fact has been communicated to the assessing authority sufficiently early as per their Lr.No.M/TCR/2010-2011 dt.25.06.2010 under proper acknowledgment. The then Assessing Authority issued a notice to the assessee under clause VI of section 8(f)(i) introduced as per Finance Act 2010, that since the dealer is doing the business under a brand name, they have to disclose the highest tax payable by the principal or the franchisee who were selling the goods in brand name Malabar God, for treating the business place as a branch or franchisee. For that notice the assess gave no reply. However, the compounding proceedings was not cancelled. Since the dealer had requested for a personal hearing, an opportunity for hearing was granted. Sri.P.Abdul Karim, Authorized Representative appeared and was heard. Since the assess has been doing business not as a branch or franchisee of Malabar Gold and since they have shifted their place of business from Door No.XXV/1130/1, City Centre, Round West to Door No. 19/441/1 &2, Sankara Iyer Junction, M.G.Road, Thrissur a more spacious show room at a conspicuous location in the heart of the city, they are not eligible to continue to pay tax under section 8 (f)(i)(v)(d) of the Act and hence the following orders are issued. ORDER NO.32080262152/2011-2012 DATED 22.06.2011 In the circumstances explained above, the application filed by M/s.Al-Ahli Business Trade Links (P) Ltd., opting to pay tax under section 8(f)(v)(d) of the KVAT Act 2003 for the year 2011-2012 at 125% of the tax paid during the previous year is rejected." As per Annexure-A3 show cause notice, the reason proposed to reject the claim was after opting for compounding dealer has shifted his place of business from City Centre, Thrissur to Sankara Iyer Junction, M.G.Road, Thrissur. Further, in spite of such shifting of place of business, dealer has not changed the address of business place and there was no intimation regarding opening of branch business place at Sankara Iyer Road. The proceedings at Annexure-A5 clearly indicates altogether a different reason for rejecting the claim of dealer. Further, proviso to Section 8(f)(ii) requires prior approval of the District Deputy Commissioner before proceeding with orders. So far as first part of the proviso, dealer must be given an opportunity of being heard. The proceedings at Annexure-A5 clearly indicates altogether a different reason for rejecting the claim of dealer. Further, proviso to Section 8(f)(ii) requires prior approval of the District Deputy Commissioner before proceeding with orders. So far as first part of the proviso, dealer must be given an opportunity of being heard. There is no application of mind so far as the reason indicated at Annexure-A3, since as early as 25.06.2010 Assistant Commissioner concerned was informed by the dealer that they were proposing to shift their place of business from City Centre, Round West, Thrissur to Sankara Iyer Junction, M.G.Road, Thrissur with effect from 01.07.2010. This is clear from Annexure-Al. Annexure-Al(3) clearly indicates, as on 28.06.2010, there is acknowledgment of such intimation by the Department with its seal. In spite of receiving intimation at Annexure-Al if the Department were to issue Annexure-A3, it amounts to non application of mind by the concerned authority. 14. On going through the contents of Annexure-A5, further deficits are revealed. From this, there is no denial of receipt of intimation at Annexure-Al. The reason for rejecting the claim was altogether different. They say, assessing officer issued notice to the dealer asking them to disclose the highest tax payable by the principal or the franchisee who were selling the goods in brand name Malabar Gold, for treating the business place as a branch or franchisee. But no reply was given. However, compounding proceedings were not cancelled initially and later, since the assess has been doing business not as a branch or franchisee of Malabar Gold and since they have shifted their place of business to a more spacious show room at a conspicuous location in the heart of the city, they are not eligible to the benefit under Section 8(f)(i)(v)(d) of the Act. So far as this reasoning of the Assistant Commissioner, no opportunity of being heard was given to the revision petitioner. The reason indicated at Annexure-A3 is altogether different from Annexure-A5. Therefore, there is no application of mind. 15. In the case of Josco Gold Corporation Pvt. Ltd. v. Commercial Tax Officer, 1st Circle, Kottayam and others ((2014) 22 KTR 58 (Ker)) a Division Bench of this Court had an occasion to deal with the provisions of Section 8(f) of the Act where new branch was opened during 201011 and permission was granted to pay compounded rate of tax for the year 2010-11. Later, opining that dealer held stock exceeding double the quantity held in the previous year, which is in violation of the mandatory provision, refused to grant permission to pay tax at compounding rate. When challenge was made to the provision on the ground of violation of freedom under Article 19(i)(g) of the Constitution, their Lordships opined that once an objective criteria is fulfilled, authority can exercise its power in terms of the statute. Therefore, challenge to Section 8(f)(ii) was repelled and the request to read down the provision on the basis of Article 14 as without any basis was also repelled. 16. In the above case, a writ petition was filed before the learned single Judge challenging the provisions of Section 8 (f)(ii) as unconstitutional if it were to be interpreted as meaning that the officer is bound to cancel the permission granted irrespective of the circumstances. Learned single Judge rejected the said contention wherein he opined that none of the circumstances which would render the statute vulnerable existed in that case. He further opined that appellant must be treated as aware of the provisions as per which there were stock exceeding double the quantity held in the previous year, the party is not entitled to compound and what is more, he is liable to be visited with an order of cancellation. The Division Bench opined that it is well settled law that Article 19(l)(g) of the Constitution confers fundamental freedom on citizens and it has to be exercised by individuals and not by a corporate body. It was further opined that the ground raised by the appellant was absolutely an objective criteria and there was no element of subjectivity, therefore the challenge to the provisions of Section 8(f) is to be rejected and the request to read down the provision deserves to be rejected. 17. In the present case, it is not a writ appeal against the orders of a learned single Judge in a writ petition. Question of considering the validity of the statute does not arise here. We are dealing with a situation where this Court is required only to see whether provisions of Section 8(f)(ii) are complied with by the authority concerned or not. As already stated above, assessing authority, only for valid and sufficient reasons, can refuse permission to pay tax at compounding rate or cancel the permission already granted. We are dealing with a situation where this Court is required only to see whether provisions of Section 8(f)(ii) are complied with by the authority concerned or not. As already stated above, assessing authority, only for valid and sufficient reasons, can refuse permission to pay tax at compounding rate or cancel the permission already granted. It says valid and sufficient reasons like shifting of *business place, furnishing of false information, etc. If shifting of business place was to be a valid and sufficient reason, instead of just opining registration is cancelled on account of shifting of place of business, assessing authority must give a valid reason why such shifting deserves such treatment. Unless such reasoning is mentioned per se, shifting of place of business may not be a ground upon which permission can be cancelled without valid and sufficient reason. In the absence of such valid and sufficient reason, it is nothing but arbitrary and illegal. As already stated above, the reasoning in the show cause notice is enlarged to much larger issue by the time permission came to be cancelled at Annexure-A5. Therefore, assessing authority has not applied its mind while cancelling the permission. Further, there was no opportunity to the assessee to explain the valid and sufficient reason to shift his place of business before cancelling the permission on the ground of shifting the place of business. Consequences of shifting the place of business being a valid and sufficient reason was never indicated in the notice at Annexure-A3. 18. That apart, proviso to Section 8(f)(ii) provides that orders, either to cancel the permission or refuse permission cannot be issued without prior approval of the District Deputy Commissioner. The original files clearly indicate no such prior approval of the District Deputy Commissioner was obtained before issuing orders under the Act. Therefore, this is also not properly indicated. The decision of the authority cancelling the permission on the ground of shifting of business place was never intimated which is nothing but perversity in appreciating the materials on record as such intimation was received and it was very much within the knowledge of the department. Having said such being a valid and sufficient reason for cancelling the permission, Annexure-A5 is entirely on a different ground for cancellation. Having said such being a valid and sufficient reason for cancelling the permission, Annexure-A5 is entirely on a different ground for cancellation. Therefore, the assessee did not have an opportunity of being heard so far as the ground upon which such permission was cancelled as per Annexure-A5 order. Further, District Deputy Commissioner's prior approval was also not obtained before issuing the order. 19. In the light of the above observations, we are of the opinion, orders of the Tribunal lacks consideration of relevant facts, in order to understand whether provisions of the statute are complied with or not. They were never discussed and under these circumstances, orders deserve to be set aside. Accordingly, the revision is allowed setting aside the orders of the Tribunal.