ORDER :

Civil Appeal No. 491 of 1977:

This appeal is preferred against the judgment of the Andhra Pradesh High Court allowing the tax revision case filed by the respondent-assessee under section 22 of the Andhra Pradesh General Sales Tax Act. The order of assessment was made in the month of September, 1969. That order was sought to be revised by the Deputy Commissioner under sub-section (2) of section 20 of the Act. After hearing the respondent, the Deputy Commissioner passed orders prejudicial to the assessee. The Deputy Commissioner says that he passed the said orders on January 6, 1973, but it was served upon the assessee only on November 21, 1973. According to section 20, an order in revision must be passed within four years of the order of assessments In this case, service of the order is after the expiry of four years from the date of the order of assessment. In the circumstances, the assessee raised a contention that the order was in fact made after the expiry of four years but was ante-dated, and therefore, it is bad. The High Court accepted this submission but on a different reasoning. The High Court was of the opinion that every order must be communicated within a reasonabl