The petitioner is a dealer under Andhra Pradesh Value Added Tax Act, 2005 (the VAT Act, for brevity) on the rolls of the second respondent. They are engaged in the sale of tyres and tubes. On 11.01.2011, the business premises was inspected on the ground that the audit and inspection day revealed that the dealer did not produce entire records and underdeclared tax, the Commercial Tax Officer, Saifabad, assessed VAT for the periods 2006-2007 to 2009-2010. Against the assessment order, dated 19.11.2011, determining the penalty of Rs.4,52,47,895/-, the petitioner preferred appeal before the Appellate Deputy Commissioner (ADC) - third respondent. They also filed an application for stay of the above mentioned disputed tax. The third respondent passed orders on 09.02.2012 directing stay of further proceedings pursuant to assessment order on condition of the petitioner paying 50% of the disputed tax. Aggrieved by the same, the petitioner filed revision under Section 31(3)(b) of the VAT Act. By impugned order, the Joint Commissioner (JC) - fourth respondent confirmed the order of the ADC.