Broad revisional power under sales tax law allows superior authority to correct defective subordinate rebate orders.

Section 12(2) of the Madras General Sales Tax Act confers broad revisional power on the superior taxing authority to call for and examine an inferior order for legality, propriety or regularity, and to pass appropriate orders. The provision is not confined to correcting only patent errors on the face of the record. That power extends to reviewing whether the subordinate officer's rebate order was correct and proper in the circumstances, including where rebate was granted without insisting on originals or following the prescribed procedure. The revisional scheme supports correction of defective subordinate orders to maintain proper fiscal .

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Issues: Whether the superior taxing authority had power under section 12(2) of the Madras General Sales Tax Act to examine and revise the order of the subordinate taxing officer on the ground of legality, propriety or regularity, and whether that power was confined only to errors apparent on the face of the record.

Analysis: Section 12(2) confers broad revisional power on the superior authority to call for and examine the record of any order passed by an inferior authority for the purpose of satisfying itself as to the legality, propriety or regularity of such order or proceeding, and to pass such orders as it thinks fit. The language of the provision does not limit interference to patent errors on the face of the record. The power extends to examining whether the subordinate order was correct, fit and proper in the circumstances, including where the subordinate authority allowed rebate without insisting on the originals and without following the prescribed procedure. The rules governing rebate applications and the revisional scheme support a construction that enables superior officers to correct defective subordinate orders in the interest of proper fiscal administration.

Conclusion: The superior authority had jurisdiction to revise the subordinate officer's rebate order, and the challenge to that revisional power failed.

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