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Issues:
1. Revision petitions challenging the order passed by the Commissioner of Agricultural Income Tax under section 54 of the Act. 2. Interpretation of the term "prejudicial to the assessee" in the context of section 34 and section 54 of the Act. 3. Reconsideration of the law laid down by the Full Bench regarding the scope of revision petitions. 4. Comparison between the decision of the Special Bench and the Full Bench regarding the interpretation of relevant sections. Analysis: 1. The revision petitions were filed against an order by the Commissioner of Agricultural Income Tax under section 54 of the Act. The court referred to a previous Full Bench decision in N. N. Seshadrinathan v. State of Madras, emphasizing that an order declining to interfere shall not be deemed prejudicial to the assessee. The court reiterated that for a revision to be valid, there must be prejudice caused to the assessee by the order under section 34 of the Act. 2. The petitioner argued that the language difference between sections 34 and 54 of the Act allows for orders not enhancing assessment but still prejudicial to be challenged. The court disagreed, stating that the term "otherwise prejudicial" in section 54 only applies if there is actual prejudice to the assessee due to the order under section 34. The court emphasized that the prejudice must be a direct consequence of the order being revised, not merely the affirmation of a previous order. 3. The petitioner sought a reconsideration of the Full Bench's decision, contending that it did not consider the language variance between sections 34 and 54. The court rejected this argument, upholding the Full Bench's ruling that an order declining to interfere under section 34 does not automatically constitute prejudice to the assessee. The court emphasized that the legislative declaration in the second proviso to section 34 is conclusive in this regard. 4. The petitioner also argued that the Full Bench should have followed the decision of the Special Bench in Voora Sreeramulu Chetty v. CIT, which was based on the Income Tax Act. However, the court noted that the Full Bench relied on the Privy Council's decision, which established that an order must result in the assessee being in a worse position to be considered prejudicial. The court concluded that the decision of the Special Bench was no longer applicable, as per the Privy Council's ruling. In conclusion, the court dismissed the revision petitions as not maintainable, emphasizing that the law laid down by the Full Bench regarding the scope of revision petitions stands. The court clarified that observations made in another case do not override the established legal principles regarding the maintainability of revision petitions under section 34 of the Act.
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