STATE OF MADRAS vs MADURAI MILLS CO., LTD.

The Supreme Court held that under Section 12(4)(b) of the Madras General Sales-tax Act, 1939, the Board of Revenue could only exercise its revisional jurisdiction within four years from the communication of the assessing authority's order. The Court ruled that the subject of the revision was solely the revised assessment order dated 28th November 1952, and not the Deputy Commissioner's order from 21st August 1954. The doctrine of merger was not applicable as the issue of cotton value exclusion was not raised in the earlier revision, thus invalidating the Board's order.