JUDGMENT

Dr. ARIJIT PASAYAT, J.—

1.Challenge in this appeal is to the judgment of a Division Bench of the Andhra Pradesh High Court dismissing the Revision Petition filed by the appellant under Section 22(1) of the Andhra Pradesh General Sales Tax Act, 1957 (in short the ‘Act’). Before the High Court challenge was to the order passed by the Sales Tax Appellate Tribunal, Andhra Pradesh (in short the ‘Tribunal’).

2.Background facts in a nutshell are as follows :

M/s. Shakthi Seeds (P) Ltd., the appellant herein, is a private limited company and they are dealers in agricultural seeds, chillies, paddy, sun-flower and other crops. It is an assessee and a registered dealer under the Act. The Commercial Tax Officer, Hyderguda Circle, Hyderabad, framed final assessment orders in respect of the turnovers for the assessment year 1992-93 granting benefit of G.O.Ms. No. 604, Rev (S), dated 9.4.1981 and G.O.Ms. No. 129 Rev(CT II), dated 14.2.1989. However, the Deputy Commissioner (CT), Abids Division, Hyderabad, on scrutiny of the assessment finalised by the Commercial Tax Officer vide his proceedings dated 16.12.1993 noticed that the appellant after purchasing chillies, paddy and sun-flower from