JUDGMENT:

BHAN, J.

1. This judgment shall dispose of Civil Appeal No. 4491 of 2002 filed against a detailed order by which the High Court has dismissed the Writ Petition filed by the appellant and the three connected appeals which have been filed by the Assessees against the dismissal of their writ petitions by the High Court following the impugned Order in Civil Appeal No. 4491 of 2002.

2. Facts are taken from Civil Appeal No. 4491 of 2002, which is the main appeal.

3. The relevant period is from November, 1994 to March, 1995 which falls in the Assessment Year 1994-95. The appellant deals in the sale of silver bars. It filed its return showing a turnover of Rs.14,33,01,470/- and paid sales tax at the rate of =%. The Assessing Authority accepted the said return and completed the assessment on 27.11.1995. Later, the Assessing Officer issued notice on 17.8.1996 proposing to reopen the assessment under Section 14(4)(c) of the Andhra Pradesh General Sales Tax Act, 1957 (for short "the Act") and bring the above turnover to tax at the rate of 2%, apart from additional tax and surcharge, on the premise that G.O. Ms No. 1092 and G.O. Ms No. 252 reducing the rate of sales tax to =% were appli