Revisional inquiry may proceed on suspicious assessment-record material, but fresh external material cannot be used to reopen assessment.

In revisional proceedings under section 21(1) of the Punjab General Sales Tax Act, 1948, further inquiry is permissible where the assessment record itself contains suspicious features suggesting bogus transactions and the inquiry remains confined to the turnover already recorded. The revising authority is not acting on fresh external material or impermissibly reopening the assessment when it examines matters germane to the existing record. On that basis, the authority may issue notice and proceed within revisional competence, but cannot use the revisional power to introduce new material for reopening the assessment.

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Issues: Whether the revising authority could initiate proceedings under section 21(1) of the Punjab General Sales Tax Act, 1948 on the basis of material appearing in the assessment record and make further inquiry, or whether it was confined only to the record without any scope for such inquiry.

Analysis: The record before the Assessing Authority showed suspicious features and indicated that certain transactions appeared to be bogus. The revising authority did not act on fresh information received from outside the record so as to reopen the assessment under the wrong provision. Instead, it proceeded on what was already available in the assessment record and made further inquiry only into matters germane to the turnover already recorded. Such inquiry was within revisional competence and did not amount to an impermissible exercise of reopening the assessment on the basis of new material.

Conclusion: The revising authority was competent to issue the notice and proceed under section 21(1); the challenge to the notice failed.

Ratio Decidendi: In revisional proceedings, further inquiry is permissible where it is founded on suspicious features already appearing in the assessment record and is confined to the turnover on record, but not where the authority seeks to introduce fresh material to reopen the assessment.

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