Prakash Krishna, J. - These two revisions have been preferred at the instance of the Commissioner of Trade Tax, U.P., Lucknow against common order passed by the Trade Tax Tribunal, Kanpur in two connected second appeal Nos. 665 of 2000 and 666 of 2005 relating to the assessment years 1996-1997 and 1997-1998 whereby and whereunder it has allowed the appeals preferred by the dealer and set aside the assessment order creating demand for trade tax as also the first appellate order remanding the matter to the assessing authority with certain directions to record findings on the issues mentioned in the appellate order.

Both these revisions relate to the same assessee and the arguments by learned counsel were advanced in respect to the revision No. 2077 of 2005 relating to the assessment year 1997-1998 with the understanding that identical controversy is involved in the companion revision. By way of clarification, it may be added that the revision No. 2077 of 2005 arises out of assessment proceedings while the connected revision No. 2074 of 2005 arises out of reassessment proceedings initiated under section 21 of the U.P. Trade Tax Act, 1948 with respect to the assessment year 19