Suo Motu Revisional Power Is Not An Assessee's Right Under Sales Tax Law

An assessee cannot invoke the suo motu revisional power under section 20 of the Andhra Pradesh General Sales Tax Act, 1957, at his own instance to seek revision of an assessment order. The statutory scheme separately provides appeal and revision remedies to an aggrieved dealer, while section 20 is reserved for specified tax authorities as a supervisory power exercisable in the interests of revenue. The provision operates as administrative machinery for correction by the authority on its own initiative, not as a substantive right of action available to the assessee.

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Issues: Whether an assessee can invoke the suo motu revisional power under section 20 of the Andhra Pradesh General Sales Tax Act, 1957, at his instance to seek revision of an assessment order.

Analysis: The statutory scheme provided specific remedies of appeal and revision to an aggrieved dealer under the Act, while section 20 conferred revisional power only on the specified tax authorities as a suo motu power. The provision was therefore intended as administrative machinery for supervisory correction in the interests of revenue, not as a substantive right of action for the assessee. Reliance was placed on the principle that a provision framed as power exercisable

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