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Issues: Whether the Commissioner, while exercising revisional powers under section 21(1), is bound by the limitation and procedural requirements of section 11-A when enhancing the taxable turnover and sales tax liability.
Analysis: The power under section 11-A is confined to the Assessing Authority and is directed to reassessment where under-assessment or escaped assessment is discovered. The Commissioner, when acting under section 21(1), exercises revisional jurisdiction to test the legality or propriety of proceedings already completed or pending before the Assessing Authority or Appellate Authority. That revisional power is not a power of reassessment, and therefore the limitation attached to section 11-A does not control it. The notice issued by the Commissioner for initiating revision is only a notice of motion under section 21 and not a notice for assessment or reassessment.
Conclusion: Section 11-A does not apply to or restrict the Commissioner's revisional powers under section 21(1), and the Commissioner was not bound by its limitation when proceeding in revision.