Revisional jurisdiction under section 32 remains distinct from reopening and rectification powers, validating revision where section 32 applies.

Section 32 revisional power was treated as independent of the assessment reopening power under section 16 and the rectification power under section 55. The availability of a wider reopening remedy to the assessing authority did not curtail the Deputy Commissioner's jurisdiction to revise an assessment where the order otherwise fell within section 32. The court held that the two provisions operated in distinct fields and that one remedy did not exclude recourse to the other. On that basis, revisional jurisdiction was validly exercised and the revision petition failed.

---

---

Issues: Whether the Deputy Commissioner had jurisdiction under section 32 to revise the assessment when the assessment could also have been reopened under section 16 or rectified under section 55.

Analysis: The power of the assessing authority to reopen an assessment under section 16 was held to be wide, but that power was not treated as restricting the Deputy Commissioner's revisional power under section 32. The two provisions were treated as conferring distinct powers on different authorities, and the availability of one remedy did not exclude resort to the other. Accordingly, where the order fell within the scope of section 32, the exercise of revisional jurisdiction was held to be valid.

Conclusion: The Deputy Commissioner had jurisdiction to revise the assessment under section 32 notwithstanding the possible applicability of sections 16 and 55, and the revision petition failed.

---