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2-1. Writ Petition No. 16098 of 1981. - For the assessment year 1970-71 the purchase turnovers of paddy effected by the petitioner amounting to Rs. 12,69,286.25 and Rs. 29,93,521.26 was brought to tax under the Act by the Commercial Tax Officer, Gangavathi "CTO", in his assessment orders made on 29th September, 1973, and 30th April, 1974. Against the said orders of the CTO the petitioner filed appeals under section 20 of the Act before the Deputy Commissioner of Commercial Taxes (Appeals), Bellary ("DC"), inter alia contending that the paddy converted into rice had not undergone manufacturing process and his purchase turnovers were not exigible to tax under section 6 of the Act. On 14th March, 1975, the DC following a Division Bench ruling of this Court in State v. B. Raghurama Shetty [1975] 35 STC 360 which had been challenged by the State in an appeal before the Supreme Court and pending, allowed the same. On 24th March, 1981, the Supreme Court allowed the said appeal filed by the State and has reversed the decision of this Court, since reported as State of Karnataka v. B. Raghurama Shetty [1981] 47 STC 369.

20. We have earlier found that the DC allowed the appeals of the petitioners following the ruling of this Court in Raghurama Shetty's case [1975] 35 STC 360 which has been reversed by the Supreme Court on 24th March, 1981. In the impugned notices, the Commissioner exercising his suo motu power of revision proposes to bring the assessment orders in conformity with the ruling of the Supreme Court, which is blinding on all courts and authorities. Any attempt by this Court in exercise of its extraordinary jurisdiction to interfere with such a course of action, far from advancing the cause of justice, would definitely defeat the cause of justice and will not be in accord with the principles enunciated by the Supreme Court in Shenoy and Company v. Commercial Tax Officer, Circle-II, Bangalore . Even assuming that there is any merit in the contention of the petitioners on the question of limitation, then also these are not fit cases in which this Court should exercise its extraordinary jurisdiction in their favour under article 226 of the Constitution.