Revisional jurisdiction cannot challenge a show cause notice; only an actual order can be revised under the sales tax scheme.

Revisional jurisdiction under section 10(3) of the U.P. Sales Tax Act extends only to the legality or propriety of an order made by an appellate or assessing authority. A show cause notice issued under section 15-A(c) is only an intimation initiating penalty proceedings and is not itself an appealable or revisable order. Because the statutory scheme distinguishes the notice from any final penalty order, a revision filed at the notice stage is not maintainable. The referred question was answered in the negative, in favour of the department and against the assessee.

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Issues: Whether the revising authority had jurisdiction to entertain a revision against a show cause notice issued under section 15-A(c) of the U.P. Sales Tax Act.

Analysis: The revisional power under section 10(3) extends only to examining the legality or propriety of an order made by an appellate or assessing authority. A notice issued under section 15-A(c) is only an intimation calling upon the dealer to show cause before penalty is imposed, and is not itself an order. The statutory scheme distinguishes between the notice initiating penalty proceedings and the final order, if any, imposing penalty. Since the revising authority can interfere only with an order and not with an antecedent notice, it had no jurisdiction at the stage when the notice was challenged.

Conclusion: The revision against the notice was not maintainable, and the answer to the referred question is in the negative, in favour of the department and against the assessee.

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