( 1 ) THIS petition under Articles 226 and 227 of the Constitution of India is directed against a notice dated February 2, 1974 issued to the petitioner by the Additional Commissioner, Sales Tax, New Delhi intimating to the petitioner that the assessment order in respect of the petitioner in respect of the assessment year 1967-68 is proposed to be revised under Section 20 (3) of the Bengal Finance (Sales Tax) Act, 1941 as extended to the Union Territory of Delhi, hereinafter referred to as the Act, in exercise of suo mota powers of revision. The petitioner has been further called upon by the same notice to show cause why the assessments as indicated in the said notice be not revised. The petitioner challenges the jurisdiction of the Additional Commissioner to issue the said notice and legality thereof.

( 2 ) THE petitioner is a Company registered under the Companies Act and, inter alia, is engaged in the business of running hotels. One of the hotels run by it is the Oberoi Inter-Continental Hotel in New Delhi, hereinafter referred to as the Hotel. For the purposes of the Act the Hotel is registered as a "dealer".

( 3 ) THE Hotel in the course of its business has five