Revisional power must rest on the assessment record, not extraneous expert opinion, for jurisdictional satisfaction.

Revisional power under section 21(2) of the Mysore Sales Tax Act, 1957 is confined to examining the legality or propriety of an assessment order on the basis of the assessment record. The authority may seek expert assistance on factual matters such as commodity classification, but it cannot substitute an external opinion for its own satisfaction or use extraneous material as the foundation for revision. The text treats the coriander classification issue as a mixed question of fact and law, yet holds that this did not justify revision based solely on the impugned expert letter. Revision notices unsupported by independent satisfaction from the record were therefore without legal basis and liable to be quashed.

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Issues: Whether the revisional authority could invoke section 21(2) of the Mysore Sales Tax Act, 1957 by relying on an external expert opinion instead of confining itself to the assessment record and reaching satisfaction as to the legality or propriety of the assessment orders.

Analysis: Revisional power under section 21(2) is exercisable to examine the legality or propriety of an assessment order on the basis of the record. The authority may consider whether the commodity falls within the statutory description only as part of that examination, and may obtain expert assistance on matters of fact. However, it cannot substitute an outside opinion for its own satisfaction or rely on material extraneous to the record as the foundation for revision. The classification question regarding coriander was treated as a mixed question of fact and law, but that did not authorise revision on the strength of the impugned expert letter alone. Since the notice did not show that the revisional authority had independently formed the requisite satisfaction from the assessment records, the exercise of jurisdiction was improper.

Conclusion: The revision notices were without legal basis and were liable to be quashed; the assessee succeeded.

Final Conclusion: Revisional proceedings under the sales tax statute must rest on the record and the authority's own satisfaction, not on extraneous opinion as a substitute for jurisdictional examination.

Ratio Decidendi: A revisional authority acting under section 21(2) cannot found revision on material outside the assessment record and must independently determine from the record whether the original order is legal or proper.

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