Reassessment of exempt turnover based on later-discovered facts upheld; revision was not the proper remedy.

Section 14(4) of the Andhra Pradesh General Sales Tax Act empowered the assessing authority to reassess turnover that had escaped assessment or been under-assessed after notice and enquiry. Where exemption had been granted on the basis that purchasers would be the last sellers in the State, later information showing branch transfers to Madras changed the factual foundation and brought the exempted turnover within reassessment. The matter was not confined to revision under section 20, because revisional power extends only to the original assessment record and not to subsequently discovered facts. The notices were therefore within jurisdiction.

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Issues: Whether the assessing authority could invoke section 14(4) of the Andhra Pradesh General Sales Tax Act, 1957 to reopen turnovers earlier exempted, or whether the matter lay only in revision under section 20 of the Act.

Analysis: Section 14(4) authorises the assessing authority to assess turnover that has escaped assessment or has been under-assessed, after notice and enquiry. The earlier exemption was granted on the footing that the purchasers would be the last sellers within the State. The later information showed that the purchasers had branch transfers to Madras, so the factual basis for the exemption had changed and the exempted turnovers became liable to reassessment. Such a matter could not be effectively dealt with in revision under section 20, because revisional jurisdiction is confined to examining the record of the original assessment and does not extend to subsequent facts discovered later. The circumstances were therefore distinguishable from cases where the error was apparent on the original record itself.

Conclusion: The assessing authority had jurisdiction under section 14(4) to reassess the turnovers on the basis of subsequent information, and the notices were not without jurisdiction.

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