K.RAVIRAJA PANDIAN,J.

In the above writ petition, the petitioner challenges the order of the Special Tribunal dated 8.7.1997 whereby the prayer of the writ petitioner to quash the demand dated 2.11.1995 under Section 24(3) of the TNGST Act has been rejected.

2. The petitioner is a registered dealer in gold and silverwares and for the assessment years 1978-79 to 1981 -82 a revised assessment order under Section 16 of the TNGST Act was passed on 17.3.1988. The petitioner carried the matter on appeal before the first appellate authority, the Appellate Assistant Commissioner, who by his order dated 8.3.1990 deleted the assessment made on the purchase turnover of old jewellery and old silverwares and also deleted the addition made on the purchase as well as sales turnover. The penalty imposed was also reduced from 150% to 50%. On further appeal, the Tribunal sustained the turnover as found by the first appellate authority, however deleted the entire penalty by its order dated 1.8.1991. Thereupon, the third respondent, assessing authority issued a fresh demand for payment of tax after giving effect to the order of the appellate authority on 20.3.1995, which was served on the as