1. The same question arises for determination in these writ applications and I am disposing them by a common judgment. Shortly stated, the question is whether the Deputy Commissioner acting under S.12(2) of the Madras General Sales Tax Act, 1939, can revise an order passed by the Appellate Assistant Commissioner after the period prescribed by R.17(1) of the Madras General Sales Tax Rules, 1939 has expired, on the ground that turnover had escaped assessment.

2. The year of assessment in each of these cases is 1953-54. On the expiry of nearly three years after the end of that year, notices were issued to the petitioners, apparently under R.17 of the Madras General Sales Tax Rules, 1939, to show cause why turnover which it was alleged had escaped assessment should not be assessed. Though the petitioners showed cause, the proceedings ended against the petitioners in that assessments were made relating to the alleged escaped turnovers. The petitioners appealed and the appellate authority by Ext. P4 in each of these cases accepted the contention of the petitioners and held that there has been no escape of turnover, that the turnover in question is not taxable and therefore set