Intervening change in law may justify revision where reasonable hearing is given and the subordinate order becomes legally incorrect.

A revisional authority under section 20(1) of the Andhra Pradesh General Sales Tax Act could consider an intervening validating enactment and later judicial decisions, because revision is a continuation of the original proceeding and may address the legality and propriety of the subordinate order in light of the law as it then stood. The Board of Revenue was therefore competent to revise the assessment order. The dealer was also held to have received a reasonable opportunity to object, since notice was served, time to respond was granted, and no prejudice beyond the legal challenge to revisional power was shown. The revisional order restoring the assessments was upheld.

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Issues: (i) Whether the Board of Revenue could exercise revisional jurisdiction under section 20(1) of the Andhra Pradesh General Sales Tax Act, 1957, by taking note of the intervening validation legislation and later judicial decisions; (ii) Whether the dealer was denied a reasonable opportunity to object to the proposed revision.

Issue (i): Whether the Board of Revenue could exercise revisional jurisdiction under section 20(1) of the Andhra Pradesh General Sales Tax Act, 1957, by taking note of the intervening validation legislation and later judicial decisions.

Analysis: The revisional power under section 20(1) was confined to examining the legality, propriety, and regularity of the subordinate order, but that power was wide enough to permit the authority to consider a subsequent change in the legal position. An appeal or revision is a continuation of the original proceeding, and the appellate or revisional authority may take note of a legal development that would have governed the assessment if it had been in force when the matter was pending before the assessing authority. The validating enactment and the later decisions therefore furnished a proper basis for interference with the Deputy Commissioner's order.

Conclusion: The Board of Revenue was competent to invoke section 20(1), and the revision was valid.

Issue (ii): Whether the dealer was denied a reasonable opportunity to object to the proposed revision.

Analysis: The dealer was served with notice and was given time to file objections, but sought an extension of two months instead of responding. The refusal of the longer extension was justified in view of the limitation problem, and the period granted was not shown to be unreasonable. No prejudice was demonstrated beyond the legal objection to the exercise of revisional power itself.

Conclusion: The dealer was not denied a reasonable opportunity.

Final Conclusion: The revisional order restoring the assessments was upheld, and the appeal failed.

Ratio Decidendi: A revisional authority may, within the statutory limits of its power, take cognizance of an intervening change in law and validly revise a subordinate order that has become incorrect in light of that change, provided a reasonable opportunity to be heard is afforded.

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