Kerala High Court
K.G. Rejimon, Proprietor vs State Of Kerala on 23 September, 2025
Author: A.Muhamed Mustaque
Bench: A.Muhamed Mustaque
1
OT.Rev.No.32 of 2023 2025:KER:70520
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR.JUSTICE A.MUHAMED MUSTAQUE
&
THE HONOURABLE MR.JUSTICE HARISANKAR V. MENON
TUESDAY, THE 23RD DAY OF SEPTEMBER 2025 / 1ST ASWINA, 1947
OT.REV NO.32 OF 2023
AGAINST THE ORDER DATED 16.06.2023 IN RP NO.CT/4057/2016-
R1/SGST OF COMMISSIONER OF STATE GOODS AND SERVICE TAXES,
THIRUVANANTHAPURAM
---------
REVISION PETITIONER/APPELLANT/ASSESSEE:
K.G.REJIMON, PROPRIETOR,
AGED 54 YEARS, M/S. THERMAL TECH ENGINEERS,
PULLUVAZHI P.O., PERUMBAVOOR, PIN - 683541.
BY ADVS.
SRI.P.S.SOMAN
SMT.T.RADHAMONY
RESPONDENT/REVENUE:
STATE OF KERALA, REPRESENTED BY ITS SECRETARY,
TAXES DEPARTMENT, GOVT. SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001.
BY SRI.V.K.SHAMSUDHEEN, SENIOR GOVERNMENT PLEADER
THIS OTHER TAX REVISION (VAT) HAVING BEEN FINALLY HEARD ON 17.09.2025,
THE COURT ON 23.09.2025 DELIVERED THE FOLLOWING:
2
OT.Rev.No.32 of 2023 2025:KER:70520
C.R.
ORDER
Harisankar V.Menon, J.
This Other Tax Revision Petition, at the instance of an
assessee under the provisions of the Kerala Value Added Tax
Act, 2003 (hereinafter referred to as the 'Act'), seeks to
challenge the suo motu steps initiated under Section 56 of the
Act, cancelling an assessment completed in his favour, as
confirmed by the Commissioner of Commercial Taxes.
2. The assessee is stated to be engaged in the trading
of "thermic fluid heater", which, according to him, attracts tax
at 4% under Entry 83(1)(f) of Schedule III to the Act. The
assessment was of the year 2009-10 by an order dated
11.11.2013, imposing tax at the rate of 12.5% on the afore
item, placing reliance on a clarification dated 12.08.2006 of the
Commissioner of Commercial Taxes, as per which, the tax
payable was at 12.5%. The assessment was challenged before
the first appellate authority by filing KVATA No.99 of 2014 and
OT.Rev.No.32 of 2023 2025:KER:70520
by the appellate order dated 31.01.2014, the first appellate
authority noticed that the clarification relied on while finalizing
the assessment has been set aside by this Court in the
judgment dated 15.02.2008 in OTA No.3 of 2008, since there
was no proper consideration of the issue by the Commissioner,
directed the Commissioner to revisit the issue afresh.
3. Consequent to the remit as above, the assessing
authority passed a fresh order dated 16.10.2015(Annexure-C),
imposing tax at 4% with respect to the products dealt with by
the assessee.
4. Later, the authority under Section 94 of the Act issued
Annexure-D order dated 07.04.2016, holding that since
"thermic fluid heaters" have not been specifically covered by
any of the entries in Schedule III, the tax applicable would be
at 12.5% as an RNR item under S.R.O.No.82/2006. Placing
reliance on the proceedings of the authority under Section 94
as above, the Deputy Commissioner, Mattanchery initiated suo
motu revisional steps to cancel the order dated 16.10.2015 in
favour of the assessee, since, according to him, the afore order
OT.Rev.No.32 of 2023 2025:KER:70520
was prejudicial to the interest of the revenue. After granting
an opportunity to the assessee, the Deputy Commissioner
issued Annexure-E order dated 03.09.2016 under Section
56(3) of the Act, cancelling the assessment order dated
16.10.2015 and remitting the matter for fresh consideration.
5. The suo motu revisional order as above was further
challenged before the Commissioner of Commercial Taxes,
essentially contending that the Deputy Commissioner did not
have any jurisdiction to invoke the power under Section 56 of
the Act. It is also contended that the assessment for the year
2009-10 cannot be finalised based on the clarificatory order
passed by the authority under Section 94, dated 07.04.2016,
relying on the judgment of the Division Bench of this Court in
Sreedhareeyam Ayurvedic Medicines (P) Ltd. and Ors. v.
State of Kerala and Anr. [(2011) 19 KTR 561 (Ker)].
The Commissioner, by his order dated 28.12.2020 (Annexure-
F), rejected the revision petition filed by the petitioner. When
the Commissioner's order was challenged by the petitioner-
assessee, this Court, by Annexure-G order dated 25.11.2022
OT.Rev.No.32 of 2023 2025:KER:70520
in O.T.Rev.No.22 of 2021, set aside the Commissioner's order
and directed fresh consideration at his hands. On the basis of
the afore remand, the Commissioner has issued Annexure-I
order, rejecting the revision petition, confirming the exercise of
suo motu powers by the Deputy Commissioner noticed as
above.
6. It is in such circumstances that the captioned revision
petition is presented by the revision petitioner-assessee.
7. Sri.P.S.Soman, the learned counsel for the revision
petitioner-assessee, would contend that:
i. The exercise of the revisional power under Section 56(1)
of the Act was erroneous insofar as the assessment was
the subject matter of an appeal, and the order, which is
now set aside, is the consequential order issued by the
assessing authority. According to him, the proper remedy
for the revenue was to challenge the first appellate order,
as prescribed by the statute, and not to set aside the con-
sequential order.
ii. Without prejudice to the above, he would contend that the
commodity dealt by the revision petitioner was assessable
only at the rate of 4% and the order issued by the
Authority under Section 94 of the Act would not apply to
OT.Rev.No.32 of 2023 2025:KER:70520
the case at hand. He submits that the item is falling under
Entry 83(1) of Schedule III to the Act, and the findings to
the contrary were without any justification.
iii. The clarificatory order (Annexure-D) dated 07.04.2016
can only have prospective operation.
8. Per contra, Sri.V.K.Shamsudheen, the learned Senior
Government Pleader, would contend that:
i. The Deputy Commissioner is perfectly within his power
to exercise the suo motu power insofar as the order
dated 16.10.2015 passed by the assessing authority was
against the clarificatory order issued by the authority
under Section 94 of the Act. According to him, it is the
error in the order dated 16.10.2015, which is sought to
be rectified by the Deputy Commissioner.
ii. He would also seek to sustain the classification of the
item as done in Annexure-D order dated 07.04.2016 by
the authority under Section 94 of the Act.
9. We have considered the rival contentions and the
connected records.
10. On an evaluation of the contentions raised as above
and the impugned orders, the questions of law raised in this
Other Tax Revision Petition are reframed as under:
OT.Rev.No.32 of 2023 2025:KER:70520
i. Whether, in the facts and circumstances of the case, the
exercise of the revisional power under Section 56 of the
Act was justified?
ii. Whether, in the facts and circumstances of the case, the
reliance placed on Annexure-D order dated 07.04.2016
for arriving at the tax payable by the revision petitioner
was justified?
iii. Is the clarificatory order dated 07.04.2016 only having a
prospective application?
11. The suo motu power exercised in the case at hand is
with reference to the provisions of Section 56 of the Act. The
afore provision reads as follows:
"Powers of revision of the Deputy Commissioner suo
motu:-
(1)The Deputy Commissioner may, of his own motion, call
for and examine any order passed or proceedings recorded
under this Act by any officer or authority subordinate to
him which in his opinion is prejudicial to the interest of the
Revenue and may make such enquiry or cause such enquiry
to be made and, subject to the provisions of this Act, may
pass such order thereon as he thinks fit.
Explanation:-- For the purpose of this section an order
passed or proceedings recorded shall be deemed to be
prejudicial to the interest of the revenue where the tax or
other amount assessed or demanded is lower than what is
actually due, either due to escapement of turnover or for
OT.Rev.No.32 of 2023 2025:KER:70520
any other reason.
(2) The Deputy Commissioner shall not pass any order
under sub-section(1) if,-
(a) the time for appeal against the order has not expired;
(b) the order has been made the subject matter of an
appeal to the Deputy Commissioner (Appeals) or the
Assistant Commissioner (Appeals) or the Appellate
Tribunal or of a revision in the High Court; or
(c) more than four years have expired from the year in
which the order referred to therein was passed.
(3) Notwithstanding anything contained in sub-section (2),
the Deputy Commissioner may pass an order under sub-
section (1) on any point which has not been decided in an
appeal or revision referred to in clause (b) of sub-section
(2), before the expiry of a period of one year from the date
of the order in such appeal or revision or before the expiry
of the period of four years referred to in clause (c) of that
sub-section, whichever is later.
(4) No order under this section adversely affecting a person
shall be passed unless that person has had a reasonable
opportunity of being heard."
12. The learned counsel for the revision petitioner
contends that the power under Section 56 of the Act cannot be
exercised, since the order of assessment was the subject
matter of an appeal, and it is the modified/consequential order
of assessment dated 16.10.2015, which is set aside, exercising
OT.Rev.No.32 of 2023 2025:KER:70520
the suo motu power. According to him, since the order dated
16.10.2015 is only a consequential order, the suo motu power
cannot be exercised, and the revenue ought to have challenged
the appellate order dated 31.01.2014.
13. However, we note that under Section 56 of the Act,
the Deputy Commissioner (presently Joint Commissioner) is
entitled to call for and examine any order passed or
proceedings recorded under this Act by any officer or authority
subordinate to him which, in his opinion, is prejudicial to the
interest of the revenue and pass such orders thereon as he
thinks fit after making the required enquiry in the matter. In
the case at hand, the assessment was originally completed by
the order dated 11.11.2013, levying the higher rate of tax by
relying on the original clarification dated 12.08.2006. In the
appeal filed, after noticing that the clarificatory order based on
which the assessment was made, had already been set aside
by this Court, the Appellate Authority issued the following
directions:
"In the judgment dated 15-2-2008 In OTA No.2 of 2008,
OT.Rev.No.32 of 2023 2025:KER:70520
the Hon'ble High Court of Kerala set aside the clarification
order passed by the Commissioner of Commercial Taxes
and remitted back to the Commissioner Commercial Taxes
to re-do the matter. So the clarification is not in force now.
But there is no observation was made by the Hon'ble High
Court in respect of the rate of tax of commodities covered
by the clarification order. Considering facts and
circumstances of the case, I am of view that it is only fair
and reasonable to re-do the assessment. The appellant is
directed to produce relevant documents connected with
the case and the assessing authority directed to consider
the case afresh in the light of above judgment. The appeal
is disposed as modified as indicated above. Ordered
accordingly."
(Underlining supplied)
Thus, the Appellate Authority only directed a reassessment in
the matter, directing the assessee to produce such other
documents in support of the claim. It is to be noticed that there
was no decision rendered as regards the tax payable by the
assessee. True, the consequential order is the one dated
16.10.2015. However, the afore order does not appear to have
addressed the issue afresh as directed by the Appellate
Authority, as seen from the following observations:
"M/s.Thermal Tech Engineers, Pulluvazhy.P.O, is an assessee
OT.Rev.No.32 of 2023 2025:KER:70520
on the rolls of this office bearing TIN: 32151392932. The
original assessment of the dealer for the year 09-10 has
been completed U/s. 25(1) of the Act vide this office
proceedings read as Ist above. Aggrieved by this order the
dealer preferred appeal before the Assistant Commissioner
(Appeals), Ernakulam and the Appellate Authority directed
to consider the case afresh in the light of the judgement
dated 15-02-2008 in OTA No.2 of 2008, of the Hon'ble High
Court of Kerala, and to modify the order accordingly. In the
circumstances as per the direction of the Assistant
Commissioner (Appeals), the original assessment of the
dealer is modified as follows."
Thus, in spite of the positive directions issued, there was no
effective reconsideration of the issue at the hands of the
Assessing Authority while issuing the order dated 16.10.2015.
The order is silent as regards the additional material, if any,
produced by the revision petitioner-assessee. When that be
so, the revision petitioner-assessee is not justified in
contending that the suo motu power under Section 56 of the
Act is not attracted, on account of the embargo under Section
56(2)(b). It is further to be noticed that Section 56 seeks to
empower the Deputy Commissioner to exercise the suo motu
power of revision as regards an "order passed" under the Act.
OT.Rev.No.32 of 2023 2025:KER:70520
Here, it is not the order dated 11.11.2013 that is revised by
the Deputy Commissioner under Section 56. Instead, it is the
order dated 16.10.2015, which is cancelled as seen from
Annexure-E order dated 03.09.2016.
14. The learned counsel for the revision petitioner-
assessee sought to rely on the judgment of a Division Bench
of this Court in OT.Rev.No.93 of 2022 dated 18.3.2025, in
support of his submissions. However, we notice that the
Division Bench in the afore case was considering a situation
where the assessment was made, subject matter of an appeal,
and the Appellate Authority has not only set aside the order of
assessment but also directed the assessing authority to pass a
modified assessment order based on the observations
contained therein. It is in such circumstances that the Division
Bench of this Court, in paragraph 7 of the judgment, found that
suo motu power cannot be exercised to set aside the
consequential assessment order, since the said order was one
issued pursuant to the directions of the Appellate Authority.
OT.Rev.No.32 of 2023 2025:KER:70520
15. However, as already noticed, the appellate order in
the case at hand (Annexure-B) has not issued any positive
directions and has only directed a revisit at the hands of the
assessing authority. In such a situation, in our opinion, the
revisional authority was justified in exercising the suo motu
power under Section 56 of the Act.
16. The second issue arising for consideration is as
regards the reliance placed on the proceedings of the Authority
under Section 94 to exercise the suo motu power. Admittedly,
the revision petitioner-assessee is stated to be engaged in the
trading of "thermic fluid heater". The proceedings at
Annexure-D specifically proceed to clarify the rate of tax with
respect to the 'thermic fluid heater'. In that order, as regards
the thermic fluid heater, it has been categorically found that
the HSN Code of the product is 8419.89.90, not appearing in
any of the Schedules to the Act, and hence assessable at the
higher rate under S.R.O.No.82/2006.
17. We notice that, though the revision petitioner-
assessee contends that the findings contained in Annexure-D
OT.Rev.No.32 of 2023 2025:KER:70520
order were incorrect, apart from harping upon Entry 83 to
Schedule III to the Act, no details of the item with specific
reference to the HSN Code, etc., are made available before the
assessing authority or the revisional authority, including the
Commissioner. Though a detailed argument note is seen
submitted before the Commissioner, the same is also silent
about the HSN Code as regards the item dealt with by the
revision petitioner-assessee. Unless and until the details of the
product were presented, the revision petitioner-assessee could
not have contended that the item is assessable with reference
to Entry 83 to Schedule III of the Act. It is not in dispute that
the entries in the various Schedules to the Act are geared to
the HSN Code. It is only if a particular entry in the Schedule
is not provided with an HSN Code, the question of application
of "common parlance or commercial parlance" arises. Here,
Entry 83 to Schedule III contains the HSN Code for each for
the sub entries. When that be so, it was for the revision
petitioner-assessee to have pointed out the HSN Code of the
product dealt by him to support the classification thereunder.
OT.Rev.No.32 of 2023 2025:KER:70520
However, such a course of action has not been adopted by the
revision petitioner-assessee in the case at hand.
18. The petitioner-assessee further contends that he had
relied on an expert opinion from a Chartered Engineer, and this
ought to have been accepted. The opinion of the Chartered
Engineer is dealt with by the Commissioner of State Tax in its
order (Annexure-I) as under:
"The expert opinion of the Chartered Engineer produced by
the Petitioner to beef up his contentions has also been
examined in detail. The report says that Thermic Fluid
Heaters is technically and by utility, a Heat Exchanger. He
has also pointed out that a Heat Exchanger Unit is not a
Heater. Eventhough there are technical similarities between
the different machines pointed out in the opinion of the
Technical expert, the HSN code based classification
followed to segregate the goods under different Schedules
of the KVAT Act 2003 do not allow the goods in question to
be included in Third Schedule of the Act taxable @ 4%. HSN
based categorisation of goods and subsequent allocation of
the same under various Schedules forms the basis of
classification under the KVAT Act and accordingly no
specific entry is seen for the goods in question in any of the
Schedules to the KVAT Act 2003. Therefore they can only
be classified under 12.5% category vide entry No.103 of
SRO 82/2006."
OT.Rev.No.32 of 2023 2025:KER:70520
As already noticed, the various entries in the Schedules to the
Act are geared to the HSN Code. True, the expert opinion is to
the effect that the thermic fluid heater is a "heat exchange
unit". However, entry 83(1)(f) to the Schedule III reads as
under:
THIRD SCHEDULE (4%)
[See Section 6(1)(a)]
Sl.No. Description of Goods HSN
Code
"83. Machinery of all kinds (other than
those specifically mentioned in this
schedule or in any other schedule,
(1) Machinery, plant or laboratory equip-
ment, whether or not, electrically heated
(excluding furnaces, ovens and other
equipment of heading 8514), for the
treatment of materials by a process in-
volving a change of temperature such as
heating, cooking, roasting, distilling,
rectifying, sterilising, pasterurising,
steaming, drying, evaporating, va-
pourising, condensing or cooling, other
than machinery or plant of a kind used
for domestic purposes instantaneous
or storage water heaters non-electric."
...........
(f) Heat exchange units 8419.50
Thus, unless and until it is shown that the HSN Code of the
product dealt with by the revision petitioner is the HSN Code
OT.Rev.No.32 of 2023 2025:KER:70520
shown in Entry 83 (1)(f), the petitioner-assessee cannot
succeed in his attempt. In the case at hand, a reading of the
various orders does not show that the revision petitioner-
assessee has relied on any HSN Code in support of his
contention. Therefore, we are of the opinion that merely by
referring to the opinion of the expert, the petitioner cannot
succeed, even assuming that the commodity is a heat
exchange unit. However, we notice that the issue has been
directed to be revisited by the proceedings under Section 56 of
the Act. Therefore, nothing prevents the petitioner-assessee
from providing the details of the product with specific reference
to the HSN Code, before the assessing authority, even when
we hold the second question against the petitioner-assessee.
19. The last issue arising for consideration is with
reference to the prospective operation of Annexure-D order
dated 07.04.2016. The revision petitioner-assessee contends
that the afore order can only apply prospectively with reference
to the provisions of Section 94(2) of the Act. Section 94 (2)
of the Act provides as under:
OT.Rev.No.32 of 2023 2025:KER:70520
"94(2) The Authority shall decide the question after giving
the parties to the dispute a reasonable opportunity to put
forward their case and produce evidence and after
considering such evidence and hearing the parties pass
orders within three months or within such time as may be
extended by the Commissioner. Commissioner may
considering the fact in issue decide whether such orders
have prospective operation only."
(Underlining supplied)
Thus, with reference to the power to issue clarification under
Section 94 of the Act, the Commissioner has been empowered
to hold that clarificatory orders would only have prospective
operation. In other words, the exercise of the power by the
Commissioner under Section 94(2) of the Act is independent
of the power of the authority to issue clarifications. The
revision petitioner-assessee has raised this contention
specifically before the Deputy Commissioner as well as the
Commissioner, relying on a Division Bench judgment of this
Court in Sreedhareeyam Ayurvedic Medicines (pvt.) Ltd.
and Ors. (supra). However, the Commissioner, while issuing
the impugned order at Annexure I, has brushed aside the afore
plea, holding that it is only when there are conflicting
OT.Rev.No.32 of 2023 2025:KER:70520
clarifications that retrospectivity is to be avoided. In our
opinion, the afore finding of the Deputy Commissioner is not
correct or legal.
20. In Sreedhareeyam Ayurvedic Medicines (pvt.)
Ltd. and Ors. (supra), the Division Bench of this Court, with
reference to the power under Section 94(2) of the Act, found
as under:
"15. The next question raised in the case is with respect to
the retrospectivity of Ext.P9 which is given partial
retrospectivity with effect from 01-04-2007. In this context,
learned Government Pleader brought to our notice the
amendment to Section 94(2) of the Act introduced by
Finance Act, 2009 with effect from 01-04-2009, which gives
power to the Commissioner to decide whether clarification
would have prospective effect, in this case, the clarification
was issued by the Commissioner with partial retrospectivity
with effect from 04-04-2007. Learned counsel for the
petitioner contended that the law is well settled in as much
as the clarification gives statutory right to collect the tax at
the rate clarified and if there is retrospective change, the
assessee will not be able to collect tax for the product for
the period prior to the new clarification. We are of the view
that the later clarification over ruling the earlier clarification
cannot have retrospective effect as the assessee's right
under the Act to collect tax is denied. We, therefore declare
OT.Rev.No.32 of 2023 2025:KER:70520
that Ext.P9 issued on 23-12-2009 will have effect only from
01-01-2010 onwards. However, since the first clarification
issued on 29-04-2006 was only on one item namely "Dhathri
Hair Oil', we do not think other dealers or
Appellants/Petitioners are entitled to the benefit of first
clarification issued only to one assessee and so much so,
they cannot claim relief entitled to the petitioner in W.P.(C)
No.1121/2010. We also notice that even though large
number of manufacturers engaged in production and
marketing of hair oil went for clarification before the
statutory authority and common orders were issued
rejecting the contention that the product is an ayurvedic
medicament, only few are contesting the same orders in
appeal before this Court and the remaining
manufacturers/dealers are paying tax at 12.5% on the same
product. We have also noticed that the items are high value
items which only the rich can afford and so much so, the
principle of classification classifying luxury items at high rate
of tax applies here also."
Similarly, the Apex Court also considered the same issue in
Reckitt Benckiser (India) Ltd. v. Commissioner,
Commercial Taxes and Others [(2008) 15 VST 10 (SC)],
holding that:
"We may also clarify that under the Act, the transactions
which have taken place prior to April 7, 2006 will not be taken
into account and the advance clarification will only apply for
OT.Rev.No.32 of 2023 2025:KER:70520
the period April 7, 2006 onwards."
Therefore, there can be no doubt that the clarification can only
apply prospectively.
21. In the case at hand, we notice that the clarificatory
order was issued only on 07.04.2016, as evidenced by
Annexure D. Under Section 30 of the Act, an assessee is
entitled to collect the tax payable by him from the purchaser
of the commodity. Hence, we are of the opinion that if the
clarificatory order dated 07.04.2016 is provided with any
retrospective operation, an assessee would be seriously
prejudiced, since it will not be possible for him to collect the
differential tax from his customer. This is especially so, since
under the Act, the Commissioner had the power to declare that
the clarification would not have prospective operation. The
reason stated in the impugned order for not exercising the
power does not appear to be legal. That being so, we are of
the opinion that the clarification at Annexure-D can be made
applicable only prospectively.
OT.Rev.No.32 of 2023 2025:KER:70520
22. In the light of the afore, we answer the first two
questions framed in paragraph 10 of this judgment in the
affirmative and in favour of the revenue. The third question
raised is also answered in the affirmative, in favour of the
assessee.
Since the third question has been answered in favour of
the assessee, the exercise of the revisional jurisdiction under
Section 56 of the Act cannot be sustained. Hence, Annexure-
E order of the Deputy Commissioner, confirmed by Annexure-I
order of the Commissioner of State Tax, is set aside.
The Other Tax Revision Petition is disposed of as above.
Sd/-
MUHAMMED MUSTAQUE, JUDGE
Sd/-
HARISANKAR V. MENON, JUDGE
ln
OT.Rev.No.32 of 2023 2025:KER:70520
PETITIONER'S ANNEXURES:
ANNEXURE A COPY OF THE CLARIFICATION NO.C7-28881/06/CT
DATED 12-08-2006 ISSUED BY THE COMMISSIONER.
ANNEXURE B COPY OF THE ORDER OF THE1ST APPELLATE AUTHORITY
IN KVATA 99/2014 DATED 31-01-2014.
ANNEXURE C COPY OF THE REVISED ASSESSMENT ORDER NO.
32151392932/2009-10 DATED 16-10 2015 ISSUED BY
THE ASSESSING AUTHORITY.
ANNEXURE D COPY OF THE CLARIFICATION ORDER NO. C3-
28881/06/CT DATED 07-04-2016 ISSUED BY THE
AUTHORITY FOR CLARIFICATION.
ANNEXURE E COPY OF THE SUO MOTU REVISION ORDER NO. M5-
2156/SM/2016 DATED 03.09.2016 ISSUED BY THE
DEPUTY COMMISSIONER, COMMERCIAL TAXES,
MATTANCHERRY FOR THE YEAR 2009-10.
ANNEXURE F TRUE COPY OF THE RP ORDER NO. CT/4057/2016-R1
DATED 28-12-2020 ISSUED BY THE COMMISSIONER.
ANNEXURE G TRUE COPY OF THE ORDER IN O.T. REVN.NO.22 OF
2021 DATED 25-11-2022 OF THE HON'ABLE HIGH
COURT.
ANNEXURE H TRUE COPY OF THE HEARING NOTE DATED 28-4-2023
FILED BEFORE THE COMMISSIONER.
ANNEXURE I COPY OF THE REVISION ORDER NO. CT/4057/2016-
R1/SGST DATED 16-06-2023 ISSUED BY THE
COMMISSIONER OF STATE TAX, SGST DEPARTMENT,
THIRUVANANTHAPURAM.
