Revisional jurisdiction under sales tax law survives rectification limits and supports retrospective validation of assessments.

The revisional power under section 9(2) of the Central Sales Tax Act, read with sections 20(1) and 20(2) of the Andhra Pradesh General Sales Tax Act, was stated to extend to appellate orders, and its exercise was held within the statutory period under section 20(3) of the State Act. Rule 14-A, which governed rectification or correction of assessments, did not curtail that separate revisional jurisdiction. A retrospective validating amendment of 1969 was treated as operative, and no material change in taxable point, turnover, or rate was shown to require a fresh reassessment. The assessments were therefore validly restored in revision.

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Issues: (i) Whether the Deputy Commissioner had jurisdiction under the Central Sales Tax Act read with the State Act to revise the appellate orders and restore the original assessment orders. (ii) Whether the revisional orders were barred by limitation under rule 14-A and whether the amended Central Sales Tax regime required fresh reassessment.

Issue (i): Whether the Deputy Commissioner had jurisdiction under the Central Sales Tax Act read with the State Act to revise the appellate orders and restore the original assessment orders.

Analysis: The revisional power under section 9(2) of the Central Sales Tax Act, read with sections 20(1) and 20(2) of the Andhra Pradesh General Sales Tax Act, empowered the Deputy Commissioner to call for and examine the record of subordinate orders. The appellate orders were within the revisional reach of that authority, and the exercise of power was made within the statutory period prescribed by section 20(3) of the State Act.

Conclusion: The revisional jurisdiction was validly exercised and the objection to competence failed, against the assessee.

Issue (ii): Whether the revisional orders were barred by limitation under rule 14-A and whether the amended Central Sales Tax regime required fresh reassessment.

Analysis: Rule 14-A dealt with rectification or correction of assessments by the original, appellate, or revisional authority in specified situations, and the four-year limit in that rule did not control the separate revisional power conferred by section 9(2) of the Central Sales Tax Act read with section 20 of the State Act. The amendment of 1969 was treated as retrospective and validating, and no change in the taxable point, turnover, or rate relevant to the disputed goods was shown to necessitate a fresh assessment. The Deputy Commissioner was therefore entitled to apply the amended law and restore the assessment order, with only the correct rate applied where necessary.

Conclusion: The challenge based on limitation and the need for fresh reassessment failed, against the assessee.

Final Conclusion: The assessments were held to be validly restored in revision, and the writ petitions failed in entirety.

Ratio Decidendi: A statutory revisional power governed by its own limitation period is not curtailed by a separate rule applicable to rectification, and a validating retrospective amendment may sustain the original assessment where no material change in the taxable levy is shown.

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