ORDER : Narsing Rao Nandikonda, J. This Tax Revision Case is filed by the petitioner- State under Section 22 (1) read with Rule 10 of the Andhra Pradesh General Sales Tax Rules, 1957 aggrieved by the order, dated 23.04.2008 in T.A.No.281 of 2001, passed by the learned Sales Tax Appellate Tribunal, Andhra Pradesh, Hyderabad (STAT). 2. The brief facts of the case are that the respondent- M/s.Bharat Heavy Electricals Limited is on the rolls of the Commercial Tax Officer, Sanga Reddy (hereinafter referred to as ‘Assessing Authority’) and after considering the findings made in the show- cause notice, dated 27.12.1997, confirmed the same and accordingly the assessment for the year 1982- 1983 under the Commercial Sales Tax Act 1956 vide GI No.12032/82-82 (CT), dated 17.04.1998 is revised as under: “Gross turnover : Rs.194,31,55,320-00 Exempted turnover: Rs. 27,69,95,453-00 Net turnover : Rs.166,61,59,867-00 3. Being aggrieved by the assessment made by the Assessing Authority, the respondent carried the matter before the learned Appellate Deputy Commissioner (CT), Secunderabad. Vide order, dated 14.03.1996, in Appeal No.C/116/87-88/NZB, the learned Appellate Deputy Commissioner after convincing and satisfied with the reasons explained by the Revenue as well as the respondent herein for the delay caused in submission of the C/D forms while condoning the delay, the learned Appellate Deputy Commissioner made the following order: (a) The Appellate Deputy Commissioner set aside the impugned Assessment Order on the disputed Turnover of Rs.17,17,82,219-00 and remanded the matter back to the Assessing Authority with a direction to re-do the assessment to the extent afresh considering the 159 C/D forms sent therein, after examining the veracity of the said forms and grant necessary relief found eligible for, in accordance with the law. (b) The learned Appellate Deputy Commissioner further observed that since the decision of the learned Tribunal has direct bearing on the disputed Turnover, the learned Appellate Deputy Commissioner dismissed the appeal on this score with a direction to the Assessing Authority to extend the benefit of reduction in rate of tax on such inter-State sales covered by Notification issued in G.O.Ms.No.403, Revenue, dated 01.05.1989. (c) The learned Appellate Deputy Commissioner also observed that the Assessing Authority did not examine and analyze the factors which in his view rendered the appellants ineligible for deduction to the extent of the disputed turnover in question herein. (c) The learned Appellate Deputy Commissioner also observed that the Assessing Authority did not examine and analyze the factors which in his view rendered the appellants ineligible for deduction to the extent of the disputed turnover in question herein. Therefore, the learned Deputy Commissioner set aside the impugned assessment on this part of the disputed turnover and remanded the matter thereon back to the Assessing Authority with a direction to re-examine the facts and circumstances involved in the disputed turnover relatable to Freight charges and re- do the assessment to the extent of afresh, in accordance with law keeping in view the observations stated supra. 4. On remand from the learned Appellate Deputy Commissioner (CT), the learned Commercial Tax Officer, Sanga Reddy, after perusal of the findings, the proposals made in the show-cause notice, dated 27.12.1997 were confirmed and accordingly the assessment for the year 1982-83 under CST Act is revised as under : “Gross Turnover : Rs.194,31,55,320-00 Exempted Turnover : Rs. 27,69,95,453-00 Net turnover : Rs.166,61,59,867-00 NTO at 4% on : Rs.166,04,55,357-00 Tax due : Rs.6,64,18,214-00 NTO at 10% on : Rs. 57,04,510-00 Tax due : Rs. 5,70,451-00 Total : Rs.6,69,89,165-00 Total tax due : Rs.6,69,89,165-00 Less Tax paid : Rs.6,39,97,170-00 Balance : Rs. 29,91,995-00” 5. Admittedly, the said orders are consequential orders pursuant to the order, dated 14.03.1996 passed by the learned Appellate Deputy Commissioner. Against the said consequential order once again a revision was preferred before learned Joint Commissioner (CT) (Legal), Office of the Commissioner of Commercial Taxes, Andhra Pradesh, Hyderabad. Learned Joint Commissioner after considering the entire evidence of both parties, vide order, dated 09.01.2001 found that the assessee has not tried to answer as to how the excess amount of Rs.1,68,58,806-00 is not taxable as proposed in the show-cause notice though it is clearly mentioned in the show cause notice that the inter unit sale of electrical goods including Excise Duty and CST Collections is Rs.5,32,00,128-44 , the Assessing Authority in its Revisional Assessment Order allowed exemption on Rs.6,86,53,241-00 . He further held that the assessee by working out two figures relating to the years 1982-1983 and 1983-1884 is not substantiated and thereby rejected the contention and finally in terms of the powers vested under Section 20 (2) of the APGST Act, 1957 read with Section 9 (2) CST 1956 he passed the Revisional Assessment Order. He further held that the assessee by working out two figures relating to the years 1982-1983 and 1983-1884 is not substantiated and thereby rejected the contention and finally in terms of the powers vested under Section 20 (2) of the APGST Act, 1957 read with Section 9 (2) CST 1956 he passed the Revisional Assessment Order. Section 20 (2) of the APGST Act, 1957 reads as follows: “20. Revision by (Commissioner of Commercial Taxes) and other prescribed authorities. (1) ……. (2) Powers of the nature referred to in sub section (1) may also be exercised by Additional Commissioner, or the joint Commissioner, Deputy Commissioner or 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-A) 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.” 6. Being aggrieved by the said order, the present Tax Revision Case is filed by the STAT before this Court contending that the Revisional Authority without considering the order of the learned Appellate Deputy Commissioner (CT) examined the consequential order and the Assessment Orders without reference to the Appellate Deputy Commissioner’s order, who passed the order of the remand and found that the Assessing Authority has allowed the exemptions without proper application of mind and without following the Rules and the Act. It is also contended that the learned Tribunal erroneously allowed the appeal without examining the merits and that the Revisional Authority without touching the order passed by the learned Appellate Deputy Commissioner (CT), revised the consequential orders passed by the Commercial Tax Officer are not in accordance with law that the Revisional Authority did not touch the learned Appellate Deputy Commissioner’s order because the Revisional Authority is not disputing the learned Appellate Deputy Commissioner (CT), remanded order disputing consequential assessment orders passed by the Commercial Tax Officer and contended that the Revisional Authority made revision of consequential order to rectify the mistake made by the Commercial Tax Officer as directed by the Appellate Deputy Commissioner and contended that it is a good in law. 7. 7. Heard Sri Chaitanya Kiran, learned counsel representing Sri Swaroop Oorilla , learned Special Government Pleader appearing for the State Tax and Sri G.Narendra Chetty, learned counsel for respondent. 8. Having perused the entire material placed on record, it is the main contention that the Tax Revision Case was contested on two grounds i.e., 1) the powers of the Revisional Authority and the scope of Revision and 2) limitation for revising the said order. Admittedly it is not an Assessment Order and it is only an effectual order. It is also contended that the said order could not have been revised. Admittedly, the order of the learned Joint Commissioner is based on and in respect of the Assessment Order Proceedings in G.I. No.12032/82- 83(CST), dated 18.01.1997 and 17.04.1998. Admittedly those orders are pursuant to the order passed by the learned Additional Deputy Commissioner (CT), vide Appeal No.C/116/ 87-88 /NZB, dated 14.03.1996 and questioning the same, the Joint Commissioner has passed order confirming the said Assessment Orders. 9. The main grievance and contention of the petitioner before this Court is that the learned Tribunal has set aside the order of the learned Joint Commissioner on the ground that the Revisional Authority without touching the order passed by the learned Appellate Authority revised the consequential orders and as there being no appeal preferred against the order of the Joint Commissioner and the order of the Appellate Deputy Commissioner (CT) order dated 14.03.1996. Hence, the learned Tribunal has rightly held that without questioning the main order, the question of challenging the revised order passed by the Assessing Authority i.e., learned Commercial Tax Officer, Sangareddy, vide order dated 18.01.1997, non est in the eye of law. 10. It is also further contended that any Assessment Order passed under the APGST Act, has to be revised within four (4) years. In the present case, the learned Appellate Deputy Commissioner (CT) passed the order on 14.03.1996. Further basing on the orders in appeal consequential orders were passed on 18.01.1997, 27.01.1997, 17.04.1998. The Revisional authority initiated revisional proceedings on 05.07.2000 and he proposed to revise the consequential orders. In the present case, the learned Appellate Deputy Commissioner (CT) passed the order on 14.03.1996. Further basing on the orders in appeal consequential orders were passed on 18.01.1997, 27.01.1997, 17.04.1998. The Revisional authority initiated revisional proceedings on 05.07.2000 and he proposed to revise the consequential orders. It is contended that on perusal of the order, the limitation under Section 20 (3) of APGST Act, the limitation for revising the order is four (4) years, as such the appeal itself filed by assessee itself is barred by limitation and as such on two grounds, the revision made by learned Appellate Deputy Commissioner is liable to be set aside. It is further contended that on perusal of the order passed by the learned Tribunal, this Court holds that the order passed by the learned Appellate Deputy Commissioner (CT) is bad in law for the reason that without revising the appellate order, revising the consequential orders is not permissible and so also the order which is passed in the said appeal is barred by limitation as the same is not questioned within four (4) years from the date of the order passed by the learned Appellate Deputy Commissioner (CT). 11. Section 20 (3) of the APGST Act, 1957, reads as follows: “20. Revision by [Commissioner of Commercial Taxes] and other prescribed authorities:- “20 (1) 20 (2) …… 20 (2A) --- 20 (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.” 12. Considering the circumstances, the learned Sales Tax Appellate Tribunal vide order, dated 23.04.2008 at paragraph No.11, it was held as follows: “In view of the above discussion we hold that the impugned orders are bad and for not touching the orders of the appellate authority but revising only the consequential orders. In view of the above discussion the appeal is allowed setting aside the impugned orders.” 13. For the aforesaid reasons, this bench is of the opinion that the order passed by the STAT is justified in allowing the appeal by setting aside the orders of the Revisional Authority. Therefore, the Tax Revision Case is deserves to be and is liable to dismissed. 14. For the aforesaid reasons, this bench is of the opinion that the order passed by the STAT is justified in allowing the appeal by setting aside the orders of the Revisional Authority. Therefore, the Tax Revision Case is deserves to be and is liable to dismissed. 14. Accordingly, the Tax Revision Case is dismissed confirming the order, dated 23.04.2008 in T.A.No.6o.281 of 2001, passed by the learned Sales Tax Appellate Tribunal, Andhra Pradesh, Hyderabad. There shall be no order as to costs. Miscellaneous petitions, if any, pending shall stand closed.