Revisional power under sales tax law cannot reopen escaped turnover assessments; that function belongs to the assessing authority.

The revisional power under the Andhra Pradesh General Sales Tax Act was confined to matters properly within the revisional field and did not extend to reopening an assessment on the footing that turnover had escaped assessment. That function belonged to the assessing authority under the separate reopening provision dealing with escaped turnover or under-assessment. Revision and reassessment were treated as distinct and mutually exclusive powers, so a revisional authority could not re-estimate turnover on the basis of escaped turnover. The enhancement made in revision was therefore invalid, and the assessee's assessment as restored by the appellate tribunal remained undisturbed.

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Issues: Whether the revisional authority under the sales tax law could enhance the turnover and reopen an assessment on the footing that part of the turnover had escaped assessment to tax.

Analysis: The power of revision under section 20 of the Andhra Pradesh General Sales Tax Act, read with the corresponding provision in the Madras General Sales Tax Act, was held to extend only to matters properly falling within the revisional field. The Court distinguished that jurisdiction from the separate power of the assessing authority under section 14(4) to deal with escaped turnover or under-assessment. A revisional authority that re-estimates turnover on the basis that a substantial part of the turnover had escaped assessment exercises a function assigned to the assessing authority, not a revisional one. The provisions governing revision and reopening were treated as embodying different and mutually exclusive concepts.

Conclusion: The revisional authority had no power to re-determine or re-estimate the turnover on the ground of escaped turnover, and the enhancement made by it was invalid.

Final Conclusion: The revision failed and the assessee's assessment as restored by the appellate tribunal stood undisturbed.

Ratio Decidendi: The power of revision does not include the power to reopen an assessment on the ground of escaped turnover, because that function belongs exclusively to the assessing authority under the reopening provision.

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