The period of limitation for revision of assessment under section 20(3) of the Andhra Pradesh General Sales Tax Act, 1957, is extended only by the period during which the revision proceedings were deferred due to an appeal or other proceeding pending before the High Court or the Supreme Court.

SYED SHAH MOHAMMED QUADRI, J.

( 1 ) ON interpretation of statutes the dicta of Parke B, which is oft quoted, is : (Extracted from the book - "maxwell on the Interpretation of Statutes", Twelfth Edition, Fourth Impression (1981) by p. St. J. Jangan at page 43.)"it is a very useful rule, in the construction of a statute, to adhere to the ordinary meaning of the words used and to the grammatical construction, unless that is at variance with the intention of the Legislature, to be collected from the statute itself, or leads to any manifest absurdity or repugnance, in which case the language may be varied or modified, so as to avoid such inconvenience, but no further. "

( 2 ) IT is the application of the above principle that is called for in this revision which is directed at the instance of the assessee-dealer against the order of the Sales Tax Appellate Tribunal, dated 17/08/1987, made in Tribunal Appeal No. 16 of 1983.

( 3 ) THE question raised in this revision relates to interpretation of sub-section (6) of section 20 of the A. P. General Sales Tax Act, 1957 (for short "the Act" ). The facts are a few and simple. The petitioner-assessee is a dealer in cement, registered under the Act. For the assessment year 1971-72 the Commercial Tax Officer, by his order of assessment dated 17/08/1972 allowed exemption on a turnover of Rs. 11,32,313 relating to freight charges and assessed a turnover of Rs. 6,75,352. 92. The Deputy Commissioner of Commercial Taxes initiated revisional proceedings against the said order of assessment, by his proceedings dated 19/02/1976. On coming to know that the same question, as was involved in the revision, was pending consideration of the High Court in Writ petition No. 236 of 1976, the order on 18/03/1976, deferring the revision proceedings. That writ petition was disposed of on 9/12/1981. After the disposal of the said writ petition, the Deputy Commissioner passed the order dated 19/06/1982, bringing to tax the exempted turnover. Against the said order of the Deputy Commissioner, the assessee went in appeal to the Sales Tax Appellate Tribunal. The main contention that was urged by the assessee before the Tribunal, was that the exercise of revisional power by the Deputy Commissioner was beyond the period of limitation prescribed under sub-section (3) of section 20 of the Act. But the Tribunal accepted the contention of the Revenue that under sub-section (6) of Section 20 the period of limitation gets extended by the period which was taken for the disposal of the case in the High court awaiting whose decision the revision proceeding were deferred and held that the exercise of revisional power was not beyond the period of limitation.

( 4 ) SRI S. R. Ashok, the learned counsel for the petitioner, contends that sub-section (6) of section 20 cannot be so interpreted as to take the benefit of a longer period than the one during which the revision proceedings were deferred as it would not only be contrary to the intention of the Legislature but would also lead to an anomalous situation.

( 5 ) THE learned Government Pleader, however, submits that the principle of liberal interpretation should be applied to the facts of this case and in so doing if the period of limitation gets extended, the benefit cannot be denied to the Revenue and that is what the Tribunal had done, as such the revision has to be dismissed.

( 6 ) TO appreciate the contention raised before us, it would be necessary to read here the provisions of sub-sections (1), (3) and (6) of section 20 of the Act which read thus :"20. Revision by Commissioner of Commercial Taxes and other prescribed authorities.- (1) The Commissioner of Commercial Taxes may suo motu call for and examine the record of any order passed or proceeding recorded by any authority, officer or person subordinate to it, under the provisions of this Act, including sub-section (2) of if such order or proceeding recorded is prejudicial to the interests of Revenue, may make such enquiry,

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