Revisional jurisdiction in valuation disputes cannot introduce a fresh basis outside the original record, though timely revision may be valid.

In revisional proceedings over a price-list approval, limitation was governed by Section 35A(4), not the notice period for short-levy or erroneous refund under Section 11A, so a notice issued within one year was timely. The revisional authority could, however, only correct or supplement the existing record; it could not introduce a fresh valuation case under Rule 6(b)(i) when the original proceedings were confined to Rule 6(b)(ii). An addendum that shifted the basis to comparable sales therefore travelled beyond the record and exceeded revisional jurisdiction. The principal legal point is that revisional power cannot be used to make out a new case on a distinct and potentially time-barred ground.

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Issues: (i) Whether the Collector's notice revising the Assistant Collector's order was barred by limitation. (ii) Whether, in revisional proceedings, the Collector could sustain an addendum introducing a new basis for valuation under Rule 6(b)(i) when the original proceedings related to Rule 6(b)(ii).

Issue (i): Whether the Collector's notice revising the Assistant Collector's order was barred by limitation.

Analysis: The dispute concerned approval of a price list and not a case of short-levy, non-levy, or erroneous refund. In such a situation, the time limit under Section 35A(4) applied rather than the notice period contemplated by Section 11A. As the revisional notice was issued within one year of the decision sought to be revised, it was not hit by limitation.

Conclusion: The revisional notice was not barred by limitation.

Issue (ii): Whether, in revisional proceedings, the Collector could sustain an addendum introducing a new basis for valuation under Rule 6(b)(i) when the original proceedings related to Rule 6(b)(ii).

Analysis: A revisional authority may supplement the record and correct defects, but it cannot use an addendum to make out an altogether new case on a fresh ground not arising from the record. The original proceedings were confined to valuation under Rule 6(b)(ii), whereas the addendum sought to shift the basis to Rule 6(b)(i) on the footing of comparable sales. That amounted to travelling beyond the record and beyond revisional jurisdiction, and the new ground was also vulnerable to limitation.

Conclusion: The addendum introducing the new ground was beyond jurisdiction and could not stand.

Final Conclusion: The appeal succeeded because the revisional order rested on an impermissible addendum introducing a new valuation basis, and the Collector's order was therefore set aside.

Ratio Decidendi: Revisional power permits correction or supplementation of existing material, but it does not authorize the authority to introduce a fresh and distinct case on a new ground outside the original record, especially where that new ground would itself be time-barred.

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