Heard Dr. A.K. Saraf, learned senior counsel assisted by Mr. S. Saikia, learned counsel for the petitioner. Also heard Mr. N.C. Phukan, learned State counsel.

2. The instant writ petition is projected against an order dated 30.4.96 passed by the Deputy Commissioner of Taxes, Tinsukia Zone, Tinsukia in exercise of suo-moto revisional powers under Section 36(1) of the Assam General Sales Tax Act, 1993 (hereinafter referred to as the Act). By order dated 25.4.91, the assessment of the petitioner for the period ending 30.9.88 was completed by the Assessing Officer under Section 9(4) of the Assam Finance (Sales) Tax Act, 1956. The aforesaid assessment order was passed after taking into consideration the report submitted by the Inspector of Taxes acting under the provisions of the Act. Tax to the extent mentioned in the assessment order was assessed and recovered. Thereafter, it appears that a notice for re-opening the aforesaid assessment under Section 18 of the Act, which had come into operation in the meantime, was issued to the petitioner on 13.8.93. The petitioner submitted his reply to the said notice on 8.10.93 which was followed by further explanations on 19.10.