- (1.) THE following question has been referred to us "whether notice of appearance as in this case could be challenged by way of direct revision to this Board under Section 14 of the Rajasthan Sales Tax Act". THE facts of the case are that the Commercial Taxes Officer, Ajmer District, while assessing Messrs Hamir Mal Sukh Raj of Beawar for the period 1-11-59 to 19-10-60 found that the assessee purchased old ornaments of gold and silver and sold in lieu thereof new ornaments. THEy, however, paid tax in respect of the sale only on the difference between the purchase price of the old ornaments and the sale price of the new ornaments, and not on the full price of the new ornaments sold. In this manner, during the said period, they had not paid tax on Rs. 28,830 He felt that the same thing may have occurred in earlier years. He, therefore, wrote a letter to Shri Dalpat Singh A. C. T. O. Beawar by his demi official letter No. nil dated 28-1-65 asking him to examine the books of accounts of the dealer right from the date of his registration as a dealer, and make a report to him. A reminder was also issued by official letter No. 592 dated 6 3 65 addressed to the A. C. T. O. Ward 'f', Beawar. A summon in form S. T. 12 (Rule 55) was thereupon issued to the assessee by the A. C. T. O. , Ward F, Beawar, on 20 3-65 calling upon him to produce the books of accounts etc. on 27-3-65 with the following words.
(2.) Varnacular Text The printed matter (pertain to personal appearance, and not leaving the office without permission, was not struck out. A revision application was filed against the summons, mainly on the following grounds: (i) Although the relevant word was Ward 'f' Beawar, the summons had in fact been signed by Shri Dinesh Narain, who was A. C. T. O. of Ward 'g', and had thus been signed by an officer not competent to do so. (ii) That the said officer had limited pecuniary jurisdiction which did not cover the assessee, whose turnover was much beyond the limit of jurisdiction of the officer. (iii) That the notice did not specify the purpose for which the books were being called. (iv) That Section 12 of the Rajasthan Sales Tax Act was not attracted,and even if it were attracted no action could be taken under it for the period earlier than the limitation prescribed in the section and, therefore, books right from the date of registration could not be called. (v) There was thus inherent lack of jurisdiction. A preliminary objection was raised before the Division Bench, which heard the revision application, that under Sec 14 (2) of the Rajasthan Sales Tax Act (under which the application had been moved) such application lies only against an 'order'. The summons not being on 'order', the application was not enter-tainable. This view had already, it was said, been held by the Board in certain cases. As the Division Bench hearing the application felt inclined to take a contrary view, this reference has come up before us. Learned counsel for the assessee drew attention to the Rajasthan High Court Judgment in Messrs. National Clinic vs. A. C. T. O. Sri Ganganagar (1966 RLW 259) in which the validity of notices under Sec. 12 of the Rajasthan Sales Tax Act (pertaining to assessment of tax incorrectly assessed) was gone into in exercise of writ jurisdiction under Article 226 of the Constitution, and in one of cases the notice was declared to be invalid. It was held in the judgment that any part of turnover had escaped assessment. It should not be 'just a suspicion based on mere gossip or rumour as it were and should be such that the officer concerned may "as an honest and reasonable person" be led to believe that there had been escapement The reason should, more over, be recorded in the notice which should be in form ST 12 A, specifically prescribed by Rule 55 A of the R. S. T. Rules for notices under Section 12. Learned counsel argued that this was a similar case. The notice was apparently intended to initiate re assessment proceedings under sec. 12 Conditions required for initating the process under that section did not, however, exist in this case. There were no definite grounds to know that any turnover had escaped tax in the years other than the one specifically required to in the C. T. O letter the A. C. T. O. , namely 1-11-59 to 19-10 60. For the other years there was mere suspicion on the part of the C. T. O. In any case, no such reason had been stated in the notice. What was stated was so vague as to amount to no reason. Moreover, he said, action under Section 12 could be initiated only by the assessing authority. The A. C. T. O. , who signed the notice, was not the assessing authority in the case of the assessee. There was thus a clear abuse of the process of law and manifest transgression of jurisdiction, and the notice deserved to be struck down, for the same reason as in the case of Messrs National Clinic cited by him. He referred to the Rajasthan High Court Judgments in Karan Singh vs. Board of Revenue (1962 RRD 141) and Rama vs. State (1962 RRD 277] to contend that the Board had vide powers under Section 84 and Section 9 of the Rajasthan Land Revenue Act to interfere and pass appropriate orders in the interest of justice. Cases like this are, he said, fit cases for such interference. He cited the Board Judgment in Shanker Stores vs. State (1968 RRD 757) to say that the Board's procedure with the Rajasthan Land Revenue Act to the extent it is not inconsistent with specific provisions in the Rajasthan Sales Tax Act, will apply to Sales Tax matters also. As an alternative argument, learned counsel said that this was not a mere notice, and had the character of an order. On the letter dated 28-1-65 from the. T. O. , the A. C. T. O. Shri Dalpatsingh had passed the order "register and then place it before me". On 20-3-65 the order on the order sheet was: Varnacular Text The notice itself required the assessee to be present with books of accounts etc. on the appointed date and directed him not to leave without permission. This was thus not a mere notice, but a notice involving a decision both in regard to assumption of jurisdiction under Section 12, where none existed, and regarding the existence of circumstances requiring action under that section. Viewed in this light, the revision application was against a decision or order, and was, therefore, enter-tainable. To a question! as to whether Sec. 12b of the R. S. T. Act would not a bar revi-sion application, he answered that the section did not apply to the present case. Section 12b lays down that "no person shall be entitled to call in question the jurisdiction of any assessing authority after the expiry of thirty days from the date of receipt by such person of any summons or notice under the Act issued by such authority or, in case the summons or notice has issued prior to the commencement of the Rajasthan Sales Tax (Amendment & Validation) Ordinance, 1967 (Rajas-than Ordinance No. 2 of 1967) after the expiry of thirty days from the commencement of the said Ordinance. " For any objection made within the prescribed time limits, it was laid down that the authority concerned would refer the question to the Commissioner who shall determine it after giving the person, raising the objection, reasonable opportunity of being heard. The Section further says that "the order made by the Commissioner shall be final". Learned counsel said that, in the present ease, not only had the notice been issued, but even the revision application challenging the notice on the basis of lack of jurisdiction had been submitted, much earlier than the ordinance referred to in Section 12b. There was no question therefore of any objection being raised after the commencement of the ordinance. The objection had already been raised before the forum then available. Even if it were assumed that the Section applied, learned counsel argued, since the legislature itself had made no provision regarding pending objections, it would be just to hold that the pending objection, in the form of the revision application, should be thrown away, and the assessee required to go afresh to the authority concerned under Sec. 12b. He cited, in support, the Allahabad High Court judgment in Om Prakash and another vs. Motilal and others (AIR 1958 Allahabad 409 ). In that a full bench of the Allahabad High Court, in a matter arising out of the substitution of Sec. 35 of the Provincial Small Cause Act (1887) by UP Act 17 of 1957 (which transferred the revisional jurisdiction from the High Court to the District Courts) decided that application already pending in the High Court in which the court had, prior to the date of coming into force of the amendment, directed the record to be called, for, may be decided by the High Court itself. This decision was based on the provisions of Sec. 6 (b) of the UP General Clauses Act and on broad considerations of justice. There was a no justification, therefore, the learned counsel said, to reject the application, and to require him to take recourse to the remedy, if any, available under Section 12 B. Regarding the phrase "shall be final" occurring in Sec. 12b learned counsel stated that this would not bar a revision application against the Commissioner's order. He cited the Board' judgment in Ved Bhushan vs. Municipal Council, Kotah, (1963 RRD 310) in support. In regard to the general objection, which he anticipated, that might be raised on behalf of the State, that normal remedies should first be exhaunted, he cited several rulings of the Supreme Court and various High Courts to the effect that the highest courts intervened to grant relief (i) where fundamental rights were infringed or (ii) where grave injustice or harassment, or unauthorised or unwarranted actions, on the part of taxing authorities were involved, or (iii) there was total lack of jurisdiction in the authorities concerned, or (iv) the errors of law or jurisdiction were obvious, or (v) even in order to clear a doubt in respect of an important question at the earliest opportunity. The judgments cited were [i] 1954 V S. T. C. 115. Supreme Court Himmatlal Harilal Mehta vs. State of Madhya Pradesh and others. (ii) 1954 V STC 401. Hyderabad High Court K. B. R. Jalingam vs. State of Hyderabad and others. (iii) 1956 VII STC 762 Hyderabad High Court Cement Market Co. , AVR Krishnamurthy. (iv) 1953 IX STC 60 Assam High Court Raja B. N. Bhup vs. Supdt. of Taxes, Dhubri, and others. (v) 1958 IX STC 648 Orissa High Court. J. N. Prusty and Bros. vs. State of (vi) 1962 XIII STC 591 Allahabad High Court Gupta & Co. vs. STO Etawah. (vii) 1968 XXI STC Rajasthan High Court Jeeya Kanwar and others vs. State of Rajasthan. In 1954 V STC 401 Srinivasachari J. made the following observations. " This is a taxing statute and different from other enactments. Being a taxing statute it is but proper that any doubt with regard to the liability to tax is made clear by the decision of the highest court in the State so that it may serve as a guidance to the taxing authorities. " Learned counsel said that the Board be pleased to adopt a similar attitude in matters that are brought up before it. To the possibility that the impugned communication may be treated as a summons calling for production of records, under Section 22 (2) of the RST Act, learned counsel's answer was three fold (i) that the provision of Section 22 operated only prior to assessment or a particular period had been completed, (ii) that the production of accounts can be required only 'for the purpose of the Act' and not capriciously, and the purpose should, therefore be stated and (iii) that the require-ment can be made only by the assessing authority or an officer not below the rank of Inspector authorised by the Commissioner. He also said that a summons under Section 22 (1) cannot be uitised where the purpose was to initiate proceedings under Section 12 For the purpose there must be a proper notice in form S. T. 12a. He also argued that the summons in this case went beyond the scope of Section 22[1] and prima facie contained an order to appear in person and to remain present until permitted to leave. He emphasised that these words had not been struck out in the summons. The learned Advocate General argued that if the Board heard revision appli-cations against mere summonses or notices, flood gates would be opened and the Board would be going beyond the scope of Section 14 (2) of the R. S. T. Act, under which revision applications by dealers lie. Regarding the effect of Sec. 12 B, he argued, that it contained a complete remedy regarding questions of jurisdiction, and covered even pending maters as the section referred to notices or summons issued prior to the commencement of the ordinance. On the commencement of the ordinance, specific procedure regarding dealing with objections regarding jurisdiction of assessing and appellate authorities came into force by legislative action, and that procedure would prevail over all others. The revision application which was submitted when this remedy did not exist, therefore, became anfractuous. The assessee should have gone to the authority who had issued the summons, namely the A. C. T. O Ward F. , Beawar. Regarding the nature of the summons he said, this was in no sense an order. It was certainly not a notice under Sec. 12. What the CTO had done by his D. O. letter was to ask his subordinate officer to examine the books of accounts of the assessee in the light of his [c T. O's] finding in respect of the accounts for the year examined by him and make a report to him. In pursuance of this, the A. C. T. O. issued a summons calling upon the assessee to produce his books of accounts for examination. Power for this is provided for in Section 22[1] If on the receipt of the A C. T O's report, the C T. O. came to the tentative belief that escapement had occurred, he would then have given a show cause notice in form 12a, giving reasons All that was being done was a bonafide effort to ascertain facts. The phrase 'for the purpose of the Act' in Section 22 (1) he said, covers the entire field of the purpose of the Act and there is no warrant or basis to hold, as contended by learned counsel for the assessee, that the section has only pre-assessment applicability. Regarding the scope of the word 'order' in Section 14, he said, there is no reason why it should not be given a meaning analogus to that in Section 2 (14) of the Civil Procedure Code, namely, "the formal expression of a decision". Even if one does not refer to the CPC, an order cannot but mean a decision of one of the authorities under the Act on a matter falling under the purview of the Act. A mere executive direction, or a mere notice or summons cannot be an 'order' within the meaning of the Act. Failure to comply with the summons does not, he said, directly and inevitably entail a penalty. If a penalty is to be imposed, a fresh opportunity of being heard has to be allowed. The summons was, therefore, in no way an order. The Board's powers of revision under Section 14 (2) of the Rajasthan Sales Tax Act, he said, are limited to revision of 'orders'. Learned counsel for the assessee in his rejoinder said that even if Section 12b could be deemed to apply to pending matters, had no applicability to cases involving patent lack of jurisdiction It would apply only to cases involving doubts regarding the jurisdiction of various assessing or appellate authorities or for resolving conflicts of jurisdiction, for instance whether the assessing authority 'x' has jurisdiction in a particular case or assessing authority 'y'. It cannot apply where an authority assumes patently unwarranted jurisdiction. He also said that merely because an objection regarding jurisdiction is not raised, jurisdiction cannot be deemed to have been conferred, any proceeding following a notice by an authority without jurisdiction would be a nullity. He cited the following rulings in support of his contention (i) AIR PC 68privy Council Raleigh Investment Col. , Ltd, vs. Governor General in Connira, and (ii) AIR 1954 SC 340 Supreme Court Karan Singh and others vs. Chaman Paswan and others. It was observed by Lord Uthwatt in the Privy Council ruling that "jurisdiction can not be given by consent It is a para judicis to take jurisdiction into consideration". He further said that, in any case, the Board was already seized of the matter on the date of commencement of the Ordinance referred to in Section 12b, and no proceedings were pending on that date before the officer who issued the notice. The assessee was, therefore, not required to approach that officer at that stage. He also invited attention to O. 16 R. 1 No. 2 Pt. 4 (Page 2575 Chitaley's commentary on the Civil Procedure Code (7th Edition) which contains the words "the summons, issued to the witness is nothing but an order of the court. . . " Even a summons would, therefore, be an order. The learned Deputy Government Advocate speaking with special permission, said that a notice or summons calling an assessee to produce his books for inspection for the purpose of the Act does not create any cause of action. The cause of action would arise, if and when as a result of the inspection, the authority concerned decided to take action for assessment, reassessment, penalty etc. Interventan by the Board at the very stage of summons or notice would lead to serious difficulties in the tax collection process. We would first deal with the arguments advanced with reference to the Board's powers. Sub-sections [1] and [2] of Section 14 of the Rajasthan Sales Tax Act, relating to revisions read as following "14. Revisions [1] The Board of Revenue may on being moved by the assessing authority, call for and examine the records of any proceedings [not being proceedings under the provisos to sub-section [3] of Sec. 11) under this Act and if it considers that any order is illegal or improper or erroneous it may pass such orders as it thinks fit. " Provided further that the Board of Revenue shall not revise an order against which application for revision has not been made within three years of the passing of such order. " (2) The Board of Revenue may on application for revision of an order (not being an order passed under the provisos to Sub sec. [3] of sec. 11) by a dealer under this Act, made within six months of the date of the order, call for the record of the proceedings in which the order complained against was passed and after examining the record, subject to the provisions of this Act, pass such order not prejudicial to the assessee, as it thinks fit: " Provided that an order declining to interfere shall be deemed not prejudicial to the assessee: " Provided further that no revision under sub-section shall be entertained upon the application of dealer [a] if he could have appealed under Section 13 and no appeal has been filed by him, or [b] if an appeal is pending before the appellate authority. " Provided also that the Board of Revenue may admit an application for revision after the said period of six months if it is satisfied that the applicant had sufficient cause for not making the application within the said period. " It is quite clear that (i) the Board may entertain revisions only being moved by the assessing authority or on an application by a dealer, [ii] the revision can be only in respect of an'order'and [iii] no revision application can be entertained if an order is appealable, and either no appeal has been filed or an appeal is pending. The Board's power of revision under the Rajasthan Sales Tax Act is limited by these factors. The rulings cited by learned counsel for the assessee relating to the intervention by the Supreme Court and the High Courts in their writ jurisdictions under Articles 32 and 226 of the Constitution have, therefore, no applicability at all. The powers of the Supreme Court and the High Courts to issue directions, orders or writs under these articles are unhampered by any such restrictions as apply to the revisional power of the Board under the Rajasthan Sales Tax Act. The Supreme Court and the High Court may intervene at any stage of the proceedings in exercise of their powers under these articles, but there is no warrant that the Board may do so. Reference was made to the Board's powers under the Rajasthan Land Revenue Act, 1956, particularly the powers of general superintendence under Section 9, which are exercisable even in judicial matters. There is, however, no corresponding section in the Rajasthan Sales Tax Act. The revisional powers under Sec. 14 of Rajasthan Sales Tax Act are also not pari materia with the powers under Sec. 14 of the Rajasthan Land Revenue Act or Section 230 of the Rajasthan Tenancy Act. For instance, there is no power under Sec. 14 of the Rajasthan Sales Tax Act to call for the record of any case suo moto, as could be exercised under Sec 84 of the Rajasthan Land Revenue Act or Sec. 230 of the Rajasthan Tenancy Act. The Board procedure under the Rajasthan Land Revenue Act may, no doubt, apply to sales tax matters also, where it is not inconsistent with the procedure laid down in the Rajasthan Sales Tax Act, as held in 1268 RRD 575, already cited. That, however, would refer to the Board's procedure alone. It cannot extend to the exercise for the purposes the Rajasthan Sales Tax Act, of powers not conferred by that Act. It is not possible, therefore, to hold that the Board can exercise in respect of Sales Tax matters powers such as those under Section 84 of the Rajasthan Land Revenue Act or Section 230 of Rajasthan Tenancy Act. The position regarding the powers of the Board under the Rajasthan Sales Tax Act has been settled by the Rajasthan High Court in its judgment in CTO Special Circle Jaipur vs. Chhaganmal Basti Mal (1970 RRD 84) and we are bound by it. Part 5 of the judgment contains the following observations "the Board of Revenue exercises limited jurisdiction under Rajasthan Sales Tax Act and that jurisdiction is to be exercised in accordance with provisions of the Act and it cannot travel beyond the provisions of the Act". As already stated, revision applications can be entertained only against 'orders'. 'orders', in the context of the Act, cannot but be interpreted to mean forma] decisions taken by various authorities under the Act, whether finally deciding a matter or deciding points or questions arising during the proceedings pertaining to it. There is no justification to hold that the term would cover each and every action of an authority, such as fixing the date and time for hearing, summoning the assessee etc. The reference in Chitaley's commentary mentioned in para 19 above is in the context of summons for witnesses, which the parties may obtain from the court. The word appears to have been used there in its general sense of a 'direction' and not in the sense of an 'order' against which an appeal or revision may lie. It has, in any case, no bearing on a summons issued by an assessing authority calling an assessee to appear with or without his books of accounts, for the purpose of assessment or any other purpose of the Act. We do not consider that the bare summonses or notices in forms S. T. 12 and S. T. 12a are orders within the meaning contemplated in Sec. 14 of the Rajasthan Sales Tax Act. Regarding the nature of the notice or summons in the present case, we shall have to consider the circumstances. As has been seen the Commercial Taxes Officer, Ajmer District, wrote a letter to the Assistant Commercial Taxes Officer, Beawar, asking him to examine the books of accounts of the assessee. He did not do so on a sudden brainwave or on the basis of mere gossip or rumour. He acted on the basis of what he found in the accounts for the year which he had himself examined. Even then, he did not jump to any conclusion in respect of other years on the basis of his finding for one year and straightaway start proceedings under Sec. 12. He decided to collect facts to satisfy himself on the point, so that any action which he may initiate may be well-founded. The circumstances do not indicate that the summons was in any way a notice under Section 12. Proceedings under that section might have ultimately followed but, as discussed above, they had not actually commenced. The summons was in the nature of a summons for production of books. As the words pertaining to personal appearance were not struck out, it may also be inferred that coupled with the summons for production of books, there was a summons to appear. That, however, would not make it a notice under Sec. 12, or an order within the meaning of Sec. 14. Such a summons or notice cannot be subject of a revision under that section. We can conceive of cases where a summons or notice to which, besides prescribed form, some direction may be added by the officer issuing it, and such direction may contain an 'order',e g. a decision seeking to determine some liability. If there is such an order involved, and the nature of the order is such that a revision would lie, then a revision may be entertained, but then this will be against the 'order' as distinct from the notice or summons, and not against the summons or notice itself. We are unable to accept the contention of learned counsel for the assessee that the provisions of Sec. 22 of the Rajasthan Sales Tax Act are only for pre-asscss-ment application and that, once assessment for a period has been completed, books of accounts for the period cannot be required to be produced, and no notice or summons under Sec. 22 (1) could be issued. Section 22, in our opinion, applies before assessment as well as after it. It is a provision intended to prevent and discover evasion or avoidance of tax, and is equally relevant before and after assessment. Even for a reassessment or assessment of escaped turnover under Section 12, a process like the one provided in Section 22 (1) is necessary. As has been observed in the Rajasthan High Court Judgment in the case of Messrs National Clinic 1966 RLW 259 (already cited vide para 6 above), it is necessary for the purpose of Section 12 to come to a belief that escapement has occurred, This has to be on the basis of reasonable grounds. The best and most reasonable, way is to look at the dealer's books. Mere complaint by some one, or even indirect knowledge from the books of another dealer, would not be adequate. The dealer's own books are the best evidence and it is only reasonable that he should be given an opportunity to show them. If a power like that in Section 22 (1) is not available, it will be impossible to check on the correctness or otherwise of complaints of evasion of tax, and the purpose of the Act would, to that extent, not be properly followed. It may also be mentioned that under Section 21 of the Rajasthan Sales Tax Act and Rule 42 of the Rajasthan Sales Tax Rules, every dealer liable to pay tax is required to maintain certain accounts. Under Rule 45, the accounts are required to be preserved for 10 years and in the case of bills or memoranda for 8 years. This provision to would have very little meaning if the accounts cannot be required be produced when needed for the fulfilment of the purpose of the Act after assessment for a year has once been completed. Section 12b is a new provision in the Act. There can be no doubt that after the commencement of the Ordinance referred to therein, jurisdiction of an assess-* ing authority or an appellate authority could be objected to under the Rajasthan Sales Tax Act, only in the manner laid down in that section. There is no warrant to hold that it will apply in one set of circumstances and not in another. We do realise that there may be doubt whether the section will apply where it is not merely a question of one assessing authority having jurisdiction instead of another, but of there being no jurisdiction under the Act at all to any assessing authority, for instance, to take an extreme case, when summonses to produce accounts are issued to a person who is patently not a dealer within the meaning of the Act. That question however, need not be decided in the present reference. Question has been raised regarding the consequences of the phrase 'shall be final' in Section 12b with reference to the order passed by the Commissioner determining the question of jurisdiction. While learned counsel for the assessee thought that this would not bar a revision application before the Board against such an order, the learned Advocate General held that all further remedies under the Act would be barred. In that interpretation, the only remedy against a bad order by the Commissioner under this section would be to invoke the writ jurisdiction of the High Court. We are not, however, called upon to pronounce on the point in this case. There may be questions pertainin to jurisdiction of officers not being, or acting as, assessing authorities or appellate authorities. There are manifestly various such authorities, officer, acting under the Act. Questions regarding their jurisdiction would not fall under Section 12b. Consequently questions of jurisdiction in respect of such officers could obviously be agitated under the Rajasthan Sales Tax Act only in the appellate or revisional proceedings, arising under the provisions of the Act, out of any 'order' which may be passed in the proceedings following the summonses or notices. It now remains to consider the question regarding matters pertaining to jurisdiction pending before the Board. In the case in AIR 1958 Allahabad, 409, the learned Chief Justice made the following observations. " It cannot be supposed that the legislature meant to do injustice. . . . . . . . . . . . It seems to be an act of injustice to require such litigants who have at a time when it was the settled practice to do so filed applications in revision in this court, engaged counsel and paid the process fees for the issue of notice, commence proceedings over again in another court; and unless I am compelled to do so, I cannot think that such was the intention of the legislature. . . . . . . . . . . . . . . " Following the maxim" Nova constitutio, futures forman imponere debet, non praeteritis" (A new state of the law ought to affect the future, not the past), and also having recourse to the provisions of the General Clauses Act relating to the 'effect of repeal', the High Court decided that the pending cases should be disposed of by the High Court itself in all cases in which, prior to the date of amendment, the court had directed that the record be called for. The circumstances here are not exactly similar, as there it was a case of the jurisdiction vesting in a higher authority having been transferred to a lower authority by amendment of a law, and the higher authority having already taken some action in a pending matter. Section 12b here does not specify transfer the Board's, existing jurisdiction to the Commissioner. However, as revision applications challenging notices on questions of jurisdiction had been entertained by the Board, it would be only proper, on broad principles of justice as indicated in Moothan C. J,' observations quoted above, that revision applications raising objections against summonses or notices, such as those covered by the provisions of Section 12b, which may at present be pending before the Board, may be disposed of by the Board. Our answer to the question referred to us, therefore, is: (i) Summons or notices in forms ST. 12 or S. T. 12a under the Rajasthan Sales Tax Act cannot be the subject of revision under Section 14 of the said Act, but (ii) Revision applications raising objections against summonses or notices, such as those covered by Section 12b of the Rajasthan Sales Tak Act (that is, pertaining to the jurisdiction of an assessing authority or appellate authority) now pending before the Board may be disposed of by the Board in the broader interests of justice. .;