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TMI Blog1994 (11) TMI 408X X X X Extracts X X X X X X X X Extracts X X X X ..... ate to the same assessee are for different assessment years. They arise out of a common order of the Tribunal dated January 15, 1986. The questions raised in these revisions are: (1) Whether the Tribunal is correct in holding that the benefit of G.O. Ms. No. 88, Revenue, dated January 28, 1977, is applicable to the assessee who is not a dealer of Andhra Pradesh; and (2) Whether the revisional ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... finished products of the steel re-rollers from the tax payable under the said Act, subject to the condition that the tax has been levied under the said Act on the sale or purchase of the raw material from which such finished products were obtained." A perusal of the above excerpt of the G.O. makes it abundantly clear that there is no condition requiring that the products of steel re-rollers shou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erve that the exercise of power under section 20 of the said Act by the revisional authority could only be on the grounds mentioned in the show cause notice, otherwise, the very purpose of affording the reasonable opportunity by giving a show cause notice would become a farce formality. The Tribunal has rightly rejected the contentions of the Government on this aspect. We, therefore, find no meri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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