The judgment of the Court was delivered by

SUJATA V. MANOHAR, J. - The applicant M/s. Siemens India Limited, are registered dealers under the Bombay Sales Tax Act, 1959. The applicants filed their returns under the Bombay Sales Tax Act, 1959, for the period 1st April, 1964, to 31st March, 1965, within the prescribed period, that is to say, before 14th May, 1965. Thereafter, the Sales Tax Officer by his assessment order dated 20th April, 1967, granted to the applicants a set-off to the tune of Rs. 88.237. In respect of this assessment order of 20th April, 1967, the Assistant Commissioner of Sales Tax, in exercise of his power of suo motu revision under section 57 of the Bombay Sales Tax Act, 1959, issued a notice dated 1st March, 1972, proposing to revise the order of the Sales Tax Officer granting the set-off. Thereafter the Assistant Commissioner, by his order dated 30th April, 1972, revised the order of the Sales Tax Officer and reduced the amount of set-off by a sum of Rs. 8,902.12. The applicants filed an appeal from this order before the Deputy Commissioner of Sales Tax. The appeal was rejected. But the Deputy Commissioner reduced the disallowance from Rs. 8,902.12 to