Revisional jurisdiction limited to the assessment record; extraneous material cannot justify reopening completed assessments.

The revisional power under section 12 was limited to scrutiny of the assessment record, and reassessment could not be sustained on material outside that record or on assumptions not supported by it. The Kerala High Court noted that the revisional authority relied on a later tribunal view treating wholesale dealers as commission agents, even though that material was not part of the original assessment record. Retrospective validation by the amending Act cured the objection based on absence of notification, but it did not authorise revision on extraneous material. The revisional orders were therefore held unsustainable.

---

---

Issues: Whether the revisional authority could sustain the reassessment orders by relying on material outside the assessment record and on a later tribunal pronouncement, and whether the revisional orders were therefore without jurisdiction or otherwise unsustainable.

Analysis: The revisional power under section 12 was held to be limited to examination of the record of assessment. The order under challenge did not meet the assessees' contention that the authority must confine itself to the existing record, and instead proceeded on an assumption that the assessees were first purchasers liable to tax. The basis for reopening was not found in the assessment records, but in a later tribunal view about wholesale dealers in the area being commission agents, which was treated as material outside the permissible revisional record. The retrospective validation by the amending Act removed the objection based on want of notification, but it did not authorise revision on extraneous material.

Conclusion: The revisional orders were unsustainable for having been founded on material outside the assessment record, and the appeals were dismissed in favour of the assessees.

Ratio Decidendi: In revisional jurisdiction, the authority must confine itself to the assessment record and cannot reopen completed assessments on the basis of extraneous material or assumptions not borne out by that record.

---