Wide revisional power under sales tax law permits assessment enhancement on additional turnover, subject to notice and statutory limits.

Section 20 of the Andhra Pradesh General Sales Tax Act, 1957 confers wide revisional power on the Board of Revenue and prescribed revisional authorities to examine subordinate records for legality, propriety and regularity, and to enhance assessment after giving the assessee notice. That revisional power is distinct from the original assessment and escaped turnover power under section 14, and is not curtailed by section 14(4). The principle applied is that enhancement in revision is permissible where the authority remains within statutory limits and does not assume the assessing authority's functions. The contrary view that section 14(4) restricts section 20 was rejected.

---

---

Issues: Whether a revisional authority under section 20(2) of the Andhra Pradesh General Sales Tax Act, 1957, can enhance an assessment and bring additional turnover to tax on the basis of the record before it, or whether such action is confined to the assessing authority under section 14(4).

Analysis: Section 20 confers wide revisional powers on the Board of Revenue and on the prescribed revisional authorities, empowering them to call for and examine the record of subordinate proceedings for legality, propriety and regularity, and, under section 20(4), to enhance an assessment after giving the assessee an opportunity to show cause. The scheme of section 14, which governs original assessment and escaped turnover in the hands of the assessing authority, does not cut down the amplitude of section 20. The Court applied the principle that revisional power is distinct from original reassessment power, and that enhancement in revision is permissible where the revisional authority acts within the statutory limits and does not trench upon functions reserved to the assessing authority. The contrary view previously taken that section 14(4) limits section 20 was not accepted.

Conclusion: The revisional authority was competent to enhance the assessment on the additional turnover, and the challenge to the order failed.

Ratio Decidendi: The revisional powers under section 20(2) and section 20(4) of the Andhra Pradesh General Sales Tax Act, 1957 are of wide amplitude and are not curtailed by section 14(4); a revisional authority may enhance an assessment where the statute so permits, provided it acts within its revisional jurisdiction and after giving notice to the assessee.

---