Revisional power cannot replace reassessment procedure for escaped turnover where the statute reserves that function to the assessing authority.

Revisional jurisdiction under section 20(3) cannot be used to assess escaped turnover where the statute specifically vests reassessment in the assessing authority under section 11A. The court held that revisional power is confined to correcting illegality, irregularity, or impropriety in an assessment order, while escaped turnover must be brought to tax only through the reassessment procedure and safeguards prescribed by that provision and the relevant rules. As the impugned action treated escaped turnover as a revisional matter, it exceeded jurisdiction and was held invalid.

---

---

Issues: Whether escaped turnover could be brought to tax in revisional proceedings under section 20(3), or whether the proper course was reassessment under section 11A by the assessing authority.

Analysis: The revisional power under section 20(3) is distinct from the power to assess or reassess escaped turnover under section 11A. The statutory scheme places reassessment of escaped turnover within the competence of the assessing authority, subject to the safeguards and limitation period prescribed by that provision and the relevant rules. Revisional jurisdiction may correct illegality, irregularity, or impropriety in an assessment order, but it cannot be used to intrude into a field specifically reserved for reassessment of escaped turnover. Since the turnover in question had escaped assessment and the Assistant Commissioner proceeded to determine and tax it on that basis, the action exceeded the revisional jurisdiction.

Conclusion: The reference was answered against the department and in favour of the assessee; proceedings for escaped turnover could not validly be taken under section 20(3) in place of section 11A.

Final Conclusion: Revisional power could not be converted into the statutory power of reassessment for escaped turnover, and the impugned action was held to be without jurisdiction.

Ratio Decidendi: Where the statute expressly vests reassessment of escaped turnover in the assessing authority, revisional jurisdiction cannot be used to assume that function or to bypass the statutory procedure and limits attached to reassessment.

---