1. These two appeals by special leave from the judgment of the High Court of Kerala involve a common question, namely, whether the revisional powers conferred on the Deputy Commissioner of Agricultural Income tax and Sales Tax under S.15(1) of the Travancore-Cochin General Sales Tax Act, 1125, hereinafter called the Act, could be exercised in the present case after the expiry of a period of three years mentioned in R.33 of the Rules framed under the Act.

2. K. E. Nainan, the respondent, was a dealer in provisions at Kallar. The assessment year with which we are concerned in these appeals are 1955-56 and 1956-57. He was also conducting auction sales of cardamom having taken out a licence under S.9 of the Act. The assessment for the year 955-56 was completed by the Agricultural Income tax and Sales tax Officer on September 5,1956. His net turnover was determined at Rs 11,448-14-9 representing the sales of provisions. Exemption was given in respect of the turnover of Rs. 96,515-15-0 of auction sales of cardamom For the second year i.e. 1955-57 the turnover of Rs. 2,39,925/-was similarly exempted. In granting these exemptions the assessee was given the benefit of the commiss