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the assessment proceedings for the previous years.

5. However, based on Entry No. 559 of the "Commodity wise rate of tax" which was published on the website of the respondents which according to him has no legal backing and force, the respondents have suo moto reopened the assessment for the financial year 2015- 16 and have directed the petitioner to discharge VAT on processed meat products @ 14.5 per cent in accordance with S. No. 559 of the said Act read with Schedule CA of the said Act. The aforesaid suo moto revisional order dated 17th March, 2022 passed under Section 85 of the said Act, was challenged by the petitioner before the Revisional Board, which was registered as Case No. 197 of 2022-23. The same was disposed of by an order dated 20th June, 2024 which forms subject matter of challenge in the present writ petition. He would submit that the petitioner questions the very jurisdiction of the respondents to include S. No. 559 in the "Commodity wise rate of tax" as published by the Directorate of Commercial Taxes on the ground that the same is ultra vires the Act and the Constitution. According to him since, the very basis of the revisional order and the subsequent review order is under challenge as being ultra-vires to the provisions of the said Act, this Hon'ble Court in exercise of its extraordinary jurisdiction is competent to entertain the same. In support of his contention, he has placed reliance on a judgment delivered by the Hon'ble Supreme Court in the case of Godrej Sara Lee Ltd. Vs. Excise and Taxation Officer-cum-Assessing Authority and Others reported in (2023) 109 GSTR