Revisional jurisdiction cannot be used to tax escaped turnover of another assessment year; original assessment power remains separate.

Revisional jurisdiction under section 15 was confined to examining the legality, propriety or regularity of the proceeding actually under revision, and could not be used to assess escaped turnover belonging to a different assessment year. Taxation of escaped turnover was an independent original function vested in the assessing authority under the relevant escape-assessment provision, not a revisional power. The Commissioner therefore lacked jurisdiction to bring the other year's turnover to tax in revision, and the revisional order was invalid and set aside.

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Issues: Whether the Commissioner, while exercising revisional powers, could bring to tax escaped turnover belonging to a different assessment year and thereby revise the assessment of that year.

Analysis: The revisional power under section 15 was confined to examining the legality, propriety, or regularity of the order or proceeding actually called for. The record summoned by the Commissioner related to the assessment for one year, but the turnover sought to be taxed belonged to another year and had not been the subject of the proceeding under revision. Taxation of escaped turnover is an independent original jurisdiction, not a revisional one, and could be exercised only by the assessing authority under the applicable escape-assessment provision.

Conclusion: The Commissioner had no jurisdiction to use section 15 to assess escaped turnover of a different year, and the order was invalid.

Final Conclusion: The appeal succeeded because the impugned revisional order was made without jurisdiction and was set aside.

Ratio Decidendi: Revisional jurisdiction is confined to correcting the legality or propriety of the proceeding actually revised and cannot be used to assume original power to assess escaped turnover belonging to another assessment year.

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