A.N.GROVER, J.

(1) THESE two appeals by special leave from the judgment of the High court of Kerala involve a common question, namely, whether the revisional powers conferred on the Deputy Commissioner of Agricultural Income-tax and Sales Tax under Section 15 (1) of the Travancore-Cochin General Sales Tax Act, 1125, hereinafter called the Act, could be exercised in the present case after the expiry of a period of three years mentioned in Rule 33 of the Rules framed under the Act.

(2) K. E. Nainan, the repondent, was a dealer in provisions at Kallar. The assessment years with which we are concerned in these appeals are 1955-56 and 1956-57. He was also conducting auction sales of cardamom having taken out a licence under Section 9 of the Act. The assessment for the year 1955-56 was completed by the Agricultural Income-tax and Sales tax Officer on 5/09/1956. His net turnover was determined at Rs. 11,448-14-9 representing the sales of provisions. Exemption was given in respect of the turnover of Rs. 96,515-15-0 of auction sales of cardamom. For the second year, i. e., 1956-57 the turnover of Rs. 2,39,925.00 was similarly exempted. In granting these exemptions the assessee