( 1 ) THESE petitions raise the question of the power of this court to grant a stay of collection of tax pending a tax revision case preferred under Section 22 of the Andhra Pradesh General Sales Tax Act.

( 2 ) AGAINST an order of assessment made by the assessing authority, an appeal is provided by section 19. A further appeal is provided by section 21 to the Sales Tax Appellate Tribunal. Apart from the above, against an order of assessment made, a power of revision is vested in the Joint Commissioner, deputy Commissioner and the Commercial Tax Officer, by sub-section (2) of of section 20. This power is confined to orders made or proceedings recorded by the authorities, officers or persons subordinate to them Similarly subsection (1) of section 20 confers the power of revision upon the Commissioner of commercial Taxes. These powers are supposed to be exercised in the interest of revenue. Against an order of the Joint Commissioner, Deputy Commissioner or the Commercial Tax Officer, under sub-section (2) of section 20, an assessee can file an appeal to the Appellate Tribunal under section 21. Section 22 provides for a revision to the High Court against the orders of