Revisional power may test an assessment record and seek further enquiry, but cannot reopen on wholly fresh information.

Revisional power under section 21(1) of the Punjab General Sales Tax Act, 1948 permits the revising authority to examine the existing assessment record, issue notice, and make further enquiry or take further evidence to test the legality or propriety of the assessment order. The critical limit is that revision cannot be used to reopen an assessment on wholly fresh information later obtained outside that record, which falls within reassessment under section 11-A. Where suspicious features are apparent from the assessment record itself, revision remains within jurisdiction.

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Issues: Whether the revising authority, while exercising revisional power under section 21(1) of the Punjab General Sales Tax Act, 1948, could issue notice and make further enquiry on the basis of suspicious features found in the assessment record, or whether such action amounted to an impermissible reopening on fresh information reserved to the Assessing Authority under section 11-A.

Analysis: The revisional power was held to extend to examination of the record already before the Assessing Authority, and to the making of further enquiry or taking further evidence for determining the legality or propriety of the assessment order. The crucial distinction was between initiating reassessment on later fresh information, which belonged to section 11-A, and scrutinising suspicious matters disclosed by the existing record, which could validly be done in revision. Since the notice was founded on suspicious features apparent from the assessment record itself, the revising authority did not exceed its jurisdiction.

Conclusion: The revising authority was competent to issue the impugned notice and to proceed in revision on the basis of the assessment record.

Final Conclusion: The challenge to the revisional notice failed, and the writ petitions were dismissed with costs.

Ratio Decidendi: A revisional authority may examine the existing assessment record and conduct further enquiry to test the legality or propriety of the assessment order, but it cannot use revisional power to reopen assessment on wholly fresh information discovered later outside that record.

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