Revisional enhancement of turnover may stand on existing records, but excessive estimates can be reduced on the facts.

Revisional power under the sales tax law could extend to enhancement of turnover on the existing record, but the enhancement had to remain reasonable on the facts. Here, the assessing and reassessing estimates were based on the same materials, and the Court found the cumulative additions excessive. The revisional order was therefore sustained in principle, but the quantum of enhanced turnover was reduced, with the taxable and tax-free ratio maintained and the further addition at the original assessment stage removed.

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Issues: Whether the revisional enhancement of turnover made on the basis of the same materials already considered at the assessment and reassessment stages was justified, and if not, to what extent the enhanced turnover should be reduced.

Analysis: The assessment was originally made on estimate under section 12(2) of the Orissa Sales Tax Act, 1947, followed by a reassessment under section 12(8) on the basis of detected suppressions. The revisional authority, acting under section 23(4), relied on the same material and concluded that the suppression was greater than that taken into account by the assessing officer. Although revisional power could extend to enhancement, the Court found the cumulative estimates adopted at successive stages to be excessive on the facts. The reassessment figures were therefore found to warrant interference to the limited extent of removing the further addition made at the original assessment stage.

Conclusion: The revisional authority's power to enhance the turnover was upheld, but the quantum of enhancement was reduced. The enhanced turnover was scaled down from Rs. 60,000 to Rs. 50,000 for 1968-69 and from Rs. 1,00,000 to Rs. 91,500 for 1969-70, with the taxable and tax-free ratio maintained.

Final Conclusion: The challenge succeeded only in part, with the revisional order modified as to quantum while the underlying revisional jurisdiction was sustained.

Ratio Decidendi: Revisional power under the sales tax law may extend to enhancement of assessment on the existing record, but the quantum must still be reasonable and supportable on the facts; where successive estimates are shown to be excessive, the Court may mould relief by reducing the enhancement.

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