JUDGMENT : M. Seetharama Murti, J. 1. WP No. 890 of 2019 is filed seeking verbatim the following reliefs: ".......to issue an appropriate writ, order or direction more particularly one in the nature of writ of mandamus or any other appropriate writ or order or direction declaring the action of the 3rd respondent in rejecting the preliminary objection of the petitioner in respect of jurisdiction through the impugned Endorsement dated 10.1.2019 as illegal, arbitrary, high handed, without authority of law and jurisdiction and in contravention of Section 32(2) of APVAT Act 2005 read with Section 9(2) of CST Act 1956 and the settled legal position and set aside the same and declare that the proposed revision by the 3rd respondent amounts to revising an order which is not in existence and got merged with the revision order of the 2nd respondent dated 19.12.2017 and also amounts to exercising revision powers for the second time which is not permissible in law and pass such other order or orders as the Hon'ble Court may deem fit and proper in the circumstances of the case as otherwise the petitioner will be put to irreparable loss and hardship." 2. WP No. 3906 of 2019 is filed seeking verbatim the following relief/s: "..to issue an appropriate writ, order or direction more particularly one in the nature of writ of mandamus or any other appropriate writ or order or direction declaring the action of the 4th respondent in rejecting the preliminary objection of the petitioner in respect of jurisdiction through the impugned Endorsement dated 1.3.2019 as illegal, arbitrary, high handed, without authority of law and jurisdiction and in contravention of Section 32(1) of APVAT Act 2005 read with Section 9(2) of CST Act 1956 and the settled legal position and set aside the same and declare that the proposed revision by the 4th respondent amounts to revising an order which is not in existence and got merged with the revision order of the 2nd respondent dated 19.12.2017 and also amounts to exercising revision powers for the second time simultaneously by the 3rd and 4th respondents which is not permissible in law and pass such other order or orders as the Hon'ble Court may deem fit and proper in the circumstances of the case as otherwise the petitioner will be put to irreparable loss and hardship." 3. We have heard the submissions of Sri Bhaskar Reddy Vemireddy, learned Counsel appearing for the writ petitioner in both the writ petitions and of learned Government Pleader for Commercial Taxes appearing for the respondents. We have perused the material record. 4. The facts discernible from the pleadings and submissions made on either side are as follows: 5. The petitioner is in the business of manufacture and sale of cement. It is a registered VAT dealer on the rolls of the 1st respondent. The manufacturing unit is at Tadipathri of Ananthapur District in Andhra Pradesh. Branches are in various States and also all over the Country. Petitioner has RMC plants in some of the States including States of Andhra Pradesh and Telangana. The petitioner's assessment for the assessment year 2011-2012 under CST Act, 1956, was completed by the 1st respondent by an order, dated 30.6.2015. Later, the 2nd respondent, by exercising the powers under Section 32(2) of the AP VAT Act read with Section 9(2) of the CST Act, 1956, issued a show-cause notice, dated 13.4.2017, proposing to revise the above said assessment order passed by the 1st respondent. However, the 2nd respondent dropped the proposed revision by proceedings, dated 19.12.2017, after considering the objections and documentary evidence produced by the petitioner. The order passed by the 2nd respondent had attained finality. It was not revised by any higher authority. Thereafter, that is, after expiry of about three and a half years from the date of passing of the assessment order by the 1st respondent, the 3rd respondent issued show-cause notice, dated 4.12.2018, proposing to revise the order of the 1st respondent once again and directed the petitioner to file objections. The petitioner by its representation, dated 15.12.2018, raised a preliminary objection regarding the jurisdiction of the 3rd respondent to revise the order of assessment passed by the 1st respondent, a second time. However, without dropping the proposed revision after duly considering the preliminary objections of the petitioner, the 3rd respondent rejected the preliminary objections of the petitioner by an endorsement, dated 10.1.2019, and directed the petitioner to file objections on the proposals in the above said pre-revision show-cause notice, dated 4.12.2018. Aggrieved thereof and also assailing the said endorsement, the first of the two writ petitions is filed. Aggrieved thereof and also assailing the said endorsement, the first of the two writ petitions is filed. In the said writ petition, on 4.2.2019, while ordering notice before admission, this Court granted interim stay of the proceedings pursuant to the show-cause notice, dated 4.12.2018, and the impugned endorsement, dated 10.1.2019. Be that as it may. While matter stood thus, the 4th respondent, by exercising the powers under Section 32(1) of AP VAT Act issued a show-cause notice, dated 14.2.2019, proposing to revise the assessment order, dated 30.6.2015, passed by the 1st respondent. The 4th respondent directed the petitioner to file objections to the said show-cause notice. The petitioner filed preliminary objections, dated 18.2.2019, inter alia stating that the revision proposed by the 4th respondent also suffers from lack of jurisdiction and it amounts to exercising revisional powers simultaneously by two different authorities. The 4th respondent, having over ruled the preliminary objections of the petitioner, issued an endorsement, dated 1.3.2019, inter alia stating that he additionally proposes to set aside even the revision orders of the 2nd respondent, dated 19.12.2017, and directing the petitioner to file objections even in respect of the issue related to setting aside of the above said revision orders of the 2nd respondent. Aggrieved thereof and also assailing the endorsement, dated 1.3.2019, of the 4th respondent, the second of the two writ petitions is filed. 6. Learned Counsel for the petitioner having drawn the attention of the Court to the timeline of events made submissions in line with the pleadings. 7. Learned Government Pleader supported the actions of both the 3rd and 4th respondents, which are impugned in these writ petitions. 8. In the light of the undisputed facts and the submissions made, it is necessary to first examine the merits of the contentions and determine as to whether the petitioner is entitled to the reliefs claimed in the two writ petitions. 9. To arrive at a just decision in the matters, it is necessary to advert to the events and the legal position. 10. Be it noted that the 1st respondent passed the assessment orders, on 30.6.2015. Thus, the assessment for the year 2011-12 under the CST Act, 1956, was completed. 9. To arrive at a just decision in the matters, it is necessary to advert to the events and the legal position. 10. Be it noted that the 1st respondent passed the assessment orders, on 30.6.2015. Thus, the assessment for the year 2011-12 under the CST Act, 1956, was completed. The 2nd respondent exercised the powers under Section 32(2) of AP VAT Act read with Section 9(2) of the CST Act, 1956, and proposed to revise the assessment order passed by the 1st respondent by issuing a show-cause notice, dated 13.4.2017. After being satisfied with the objections filed by the petitioner and after getting confirmations from the officers concerned and on facts and on the strength of the confirmation report received from the State Tax Officer, Arakkonam, the 2nd respondent dropped the proposed revision and directed the 1st respondent to give effect to her orders. The said order of the 2nd respondent not having been revised by any higher officer has become final. 11. The petitioner now contends that the 3rd respondent, who issued a show-cause notice proposing to revise the order of the 1st respondent, without proposing to revise the revision order of the 2nd respondent, has no jurisdiction to revise the order of the 1st respondent, a second time, in view of the fact that the order of the 1st respondent is not available to be revised, since merged with the revision order of the 2nd respondent. The petitioner also submits that when such a preliminary objection was raised for the revision proposed by the 3rd respondent, the 3rd respondent illegally rejected the same by the endorsement, which was impugned in the first writ petition and proposed to continue with the proposed revision by directing the petitioner to file objections. Learned Counsel for the petitioner submits that as per settled law, the assessment order passed by the 1st respondent, which was once a subject-matter of revision by the 2nd respondent, cannot be subjected to revision, a second time, by the 3rd respondent and that in-fact, this Court in the first of the two writ petitions suspended the show-cause notice as well as the endorsement issued by the 3rd respondent. 12. 12. Before proceeding further, it is to be first examined as to whether the 3rd respondent is having jurisdiction and is legally justified in proposing to revise the assessment order passed by the 1st respondent a second time even without proposing to revise the revision order passed by the 2nd respondent. 13. The relevant provision in Section 32 of AP VAT Act reads as under: 32. Revision by Commissioner and other prescribed authorities:--(1) The Commissioner may suo moto call for and examine the record of any order passed or proceeding recorded by any authority, officer or person subordinate to him under the provisions of the Act, including sub-section (2) and if such order or proceeding recorded is prejudicial to the interests of revenue, may make such enquiry, or cause such enquiry to be made and subject to the provisions of the Act, may initiate proceedings to revise, modify or set aside such order or proceeding and may pass such order in reference thereto as he thinks fit. (2) Powers of the nature referred to in Sub-section (1) may also be exercised by the Additional Commissioner, Joint Commissioner, Deputy Commissioner and Assistant Commissioner in the case of orders passed or proceedings recorded by the authorities, officers or persons subordinate to them: Provided that the power under sub-section (1) or (2) shall not be exercised by the authority specified therein in respect of any issue or question, which was decided on appeal by the Appellate Tribunal under Section 33. (3) In relation to an order of assessment passed under the Act, the powers conferred by sub-sections (1) and (2) shall be exercisable only within a period of four years from the date on which the order was served on the dealer. (4) No order shall be passed under Sub-section (1) of (2) enhancing any assessment unless an opportunity has been given to the dealer to show-cause against the proposed enhancement. (5) Omitted (6) Where an order, passed under this section, has been set aside by any Court or other competent authority under the Act for any reason, the period between the date of such revision order and the date of receipt of the order, setting it aside, and also a further period of 90 days 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. (7) Where any proceeding under this section has been deferred or stayed by the Appellate Tribunal or to the High Court or by the Supreme Court for any reason, the period, during which such order of deferment or stay was in force, and also a further period of 90 days from the date of receipt of the orders, having the effect of vacation of such orders of deferment or stay, shall be excluded in computing the period of four years specified in sub-section (3) for the purpose of exercising the power under this section. Provided that on vacation of the orders of deferment or stay, referred to in the section, the proceedings of such revision shall recommence from the stage at which it was deferred or stayed. As per the provision of law, a superior officer specified in the provision of law may suo motu call for and examine the record of any order passed or proceeding recorded by any authority, officer or person subordinate to him under the provisions of the Act, including sub-section (2) and if such order or proceeding recorded is prejudicial to the interests of revenue, may make such enquiry, or cause such enquiry to be made and subject to the provisions of the Act, may initiate proceedings to revise, modify or set aside such order or proceeding and may pass such order in reference thereto as he thinks fit. In the case on hand, the 2nd respondent had already initiated proceedings to revise the assessment order passed by the 1st respondent and accordingly examined the correctness of the assessment order, on facts and on the strength of the confirmations received from the officer concerned and the 2nd respondent dropped the revision proceedings, having found that the assessment order passed by the 1st respondent is correct. In our considered opinion, the authorities concerned have no power to exercise the revisional jurisdiction more than once. In other words, since the order of the 1st respondent was once subjected to revision by the 2nd respondent, neither the 3rd respondent nor the 4th respondent can subject the same order of the 1st respondent to revision a second time. In our considered opinion, the authorities concerned have no power to exercise the revisional jurisdiction more than once. In other words, since the order of the 1st respondent was once subjected to revision by the 2nd respondent, neither the 3rd respondent nor the 4th respondent can subject the same order of the 1st respondent to revision a second time. The 3rd respondent if he intended to revise the order of the 1st respondent, he could not have proposed to subject the order of the 1st respondent to revision by a pre-revision show-cause notice without also proposing to revise the revision order of the 2nd respondent whereby the assessment order passed by the 1st respondent was confirmed. This is so, in view of the fact that the order of the 1st respondent independently is not available for revision since it merged with the revision order of the 2nd respondent in the light of the well settled principle enshrined in the doctrine of merger. In that view of the matter, we see acceptable merit in the contention of the petitioner that the action of the 3rd respondent in proposing to revise, a second time, the assessment order passed by the 1st respondent, without proposing to revise the revision order passed by the 2nd respondent, is without jurisdiction and that the said action is unsustainable under facts and in law. As a sequel, we hold that the first writ petition deserves to be allowed. 14. Now turning to the merits of the second writ petition, it is necessary to refer to the relevant events. 15. Notwithstanding the pendency of the first writ petition and the interim orders granted in the said writ petition, the 4th respondent once again issued a show-cause notice, dated 14.2.2019, proposing to revise the assessment order of the 1st respondent. The petitioner raised a preliminary objection on the point of jurisdiction. Over ruling the said objections, the 4th respondent, having decided to continue to proceed with the proposed revision, rejected the preliminary objections of the petitioner by the endorsement impugned in the second writ petition; and, by the said endorsement he directed the petitioner to file objections to the pre-revision show-cause notice inter alia stating that he also proposes additionally to set aside even the revision orders of the 2nd respondent. 16. 16. While dealing with the action of the 3rd respondent in proposing to revise a second time, the assessment order passed by the 1st respondent, without proposing to revise the revision order passed by the 2nd respondent, we have already held that the said action is one without jurisdiction and is unsustainable under facts and in law. On the same analogy, it is to be held that the action of the 4th respondent in proposing to revise the assessment order passed by the 1st respondent, a second time, without proposing to, revise, the revision order passed by the 2nd respondent, is without jurisdiction and unsustainable under facts and in law as the assessment order passed by the 1st respondent is independently not available for being subjected to revision as it merged with the revision order of the 2nd respondent. 17. This takes us to the aspect as to whether the 4th respondent can be permitted to now revise the assessment order passed by the 1st respondent and also the revision order passed by the 2nd respondent in view of his additional proposal in the endorsement, dated 1.3.2019, which is impugned in the second writ petition. In this impugned endorsement, it is stated that he now proposes to additionally set aside even the revision order of the 2nd respondent and the petitioner was directed to file objections even in respect of the issue proposing to set aside the revision order of the 2nd respondent. 18. On this aspect, learned Counsel for the petitioner specifically contended as follows:-- "The contents of the pre-revision show-cause notice issued by the 3rd respondent and the pre-revision show-cause notice issued by the 4th respondent are exactly the same in all respects except for the dates, signatures and designations of the said officers, who issued the said notices. Since the action of the 3rd respondent is questioned in the first writ petition, he is having an ill motive against the petitioner and he was responsible for the issuance of the pre-revision show-cause notice by the 4th respondent with verbatim the same content. Further, the 3rd respondent already proposed to revise the assessment order passed by the 1st respondent without proposing to revise the revision order passed by the 2nd respondent. The said revision proceedings, in view of the interim orders passed in the first writ petition, have not reached a logical conclusion. Further, the 3rd respondent already proposed to revise the assessment order passed by the 1st respondent without proposing to revise the revision order passed by the 2nd respondent. The said revision proceedings, in view of the interim orders passed in the first writ petition, have not reached a logical conclusion. Till the revision proposed by the 3rd respondent gets culminated in a revision order that may be passed in that revision proposed by him, the 4th respondent is not entitled to simultaneously initiate one more revision proceedings during the pendency of the revision proceedings initiated by the 3rd respondent. The entire record, in view of the pendency of the revision initiated by the 3rd respondent, is supposed to be in the custody of the 3rd respondent. Therefore, there is no scope for the 4th respondent to go through the record before issuing the pre-revision show-cause notice, dated 14.2.2019. Further, the said pre-revision show-cause notice merely mentions that the assessment record and assessment orders are examined. There was no mention in the pre-revision show-cause notice that the revision record of the 2nd respondent and the revision order passed by the 2nd respondent were examined; and, in-fact since there was no proposal to revise the revision order of the 2nd respondent, the 4th respondent obviously did not examine the revision record and the revision order passed by the 2nd respondent. Therefore, a mere observation in the endorsement impugned in the second writ petition that the 4th respondent now proposes to even revise the revision order of the 2nd respondent does not justify the action of the 4th respondent in proposing to revise the revision order of the 2nd respondent. Without stating the jurisdictional facts and the grounds on which the 4th respondent now proposes to revise even the revision order of the 2nd respondent, if the petitioner is required to meet such proposed action, the same would result in prejudice to the petitioner.' 19. Per contra, learned Government Pleader contended as follows:--'The principal objection of the petitioner is that either the 3rd respondent or the 4th respondent has no jurisdiction to revise the assessment order passed by the 1st respondent without proposing to revise the revision order of the 2nd respondent. Per contra, learned Government Pleader contended as follows:--'The principal objection of the petitioner is that either the 3rd respondent or the 4th respondent has no jurisdiction to revise the assessment order passed by the 1st respondent without proposing to revise the revision order of the 2nd respondent. Since no revision orders are passed by the 3rd respondent in view of the pendency of the first writ petition and since his action is without jurisdiction even according to the petitioner and as it is possible to come to a conclusion that the action of the 3rd respondent is without jurisdiction and non est, the 4th respondent is justified in initiating the revision proposed by him and also in now proposing to revise the revision order of the 2nd respondent as stated in his endorsement, dated 1.3.2019, as the said proposal is admittedly not barred by time. 20. We have given earnest consideration to the rival submissions aforestated. 21. Be it noted that in the endorsement, dated 1.3.2019, though it is stated that the 4th respondent now proposes to even revise the revision order of the 2nd respondent, yet, either in the pre-revision show-cause notice, which was issued originally proposing to only revise the assessment order of the 1st respondent, or in the aforesaid endorsement there is no reference to any grounds or jurisdictional facts on which the 4th respondent proposes to revise the revision order of the 2nd respondent as well. In neither the pre-revision show-cause notice nor the endorsement there is a mention that the 4th respondent called for the revision records and perused the said records and also the revision order passed by the 2nd respondent. In any pre-revision show-cause notice, the officer proposing to revise any order passed by the subordinate has to make a brief mention atleast that the said officer, who is proposing to exercise revisional jurisdiction, perused the order and the record related to the order, which he is proposing to revise, and as to what error has been committed by the subordinate officer in passing the order being proposed to be revised and in what manner such order is prejudicial to the interests of the Revenue. The officer proposing to initiate a revision must also show or indicate in the pre-revision show-cause notice that his conclusion that the order proposed to be revised is erroneous and prejudicial to the revenue of the State is based on material on record of the proceedings called for by him. If there is no such material on record, it can be said that the very initiation of proceedings by him would be illegal and without jurisdiction. (See: CIT v. Gabriel India Limited, 1993 (203) ITR 108 (Bom.)). Merely because the assessee contended that the superior officer cannot revise the assessment order passed by the 1st respondent without revising the revision order passed by the 2nd respondent, the 4th respondent is not well within his jurisdiction to say that he would now revise the revision order of the 2nd respondent as well, as for the initiation of a revision proposing to revise the revision order of the 2nd respondent, the 4th respondent is required I to justify such proposal as required under facts and in law by making a mention of the necessary material on jurisdictional facts in the pre-revision show-cause notice or at least in the impugned endorsement. As already noted, neither the pre-revision show-cause notice nor the endorsement impugned in the second writ petition contain the necessary material and jurisdictional facts. Therefore, we find acceptable merit in the I contentions of the petitioner that by merely stating in the impugned endorsement, dated 1.3.2019, that he proposes to now revise the revision order of the 2nd respondent, the 4th respondent cannot now propose to revise the revision order of the 2nd respondent without fulfilling the legal requirements for doing so and by making a mere bare mention of the proposal in the impugned endorsement. 22. For the aforesaid reasons, we find that the petitioner made out valid and sufficient grounds to grant the reliefs sought for in the second writ petition. 23. In the result, both the writ petitions are allowed as prayed for. 24. As a sequel, miscellaneous petitions pending in these writ petitions shall stand dismissed. No order as to costs.