IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA TAX REVISION CASE No.229 of 2010 Date:23.02.2026 Between:

M/s. Bharat Petroleum Corporation Limited, Secunderabad.

…Petitioner AND State of Andhra Pradesh rep. by its State Representative before Sales Tax Appellate Tribunal, Nampally, Hyderabad.

…Respondent ORDER : (per Hon’ble Sri Justice P.Sam Koshy)

Heard Mr.Karthik Ramana Puttamreddy, learned counsel appearing for the petitioner and Mr.Swaroop Oorilla, learned Special Government Pleader for State Tax, appearing for the respondent.

Perused the record.

2. The challenge in the Tax Revision Case is to the order dated 02.12.2009 passed in T.A.No.1552 of 2004 by the learned Sales Tax Appellate Tribunal, Andhra Pradesh, Hyderabad, (hereinafter, referred as ‘Tribunal’), respectively.

3. Vide order dated 02.12.2009, the Tribunal dismissed the appeal of the assessee on the ground that the same was barred by limitation in terms of the provisions of the Andhra Pradesh General Sales Tax Act, 1957 ( for short “ the APGST Act.”).

4. According to the petitioner, the period of assessment involved in the