Suo motu revisional power extends beyond the initiating ground and allows all legality and propriety issues to be examined.

Under section 21(1) of the Punjab General Sales Tax Act, the Commissioner's suo motu revisional power is not confined to the specific ground on which revision was initiated. The revisional authority may examine any question appearing from the record that affects the legality or propriety of the subordinate order, whether it supports the revenue or the assessee. The assessee cannot be barred from raising other objections that were decided against it by the appellate authority. This construction treats suo motu revision as a wide power of review over legality and propriety, not a limited inquiry into one isolated issue.

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Issues: Whether, in suo motu revision proceedings under section 21(1) of the Punjab General Sales Tax Act, 1948, the Commissioner could examine questions beyond the specific point on which revision was initiated and the assessee could be precluded from raising other objections decided against it by the appellate authority.

Analysis: Section 21(1) empowers the Commissioner, on calling for the record, to satisfy himself about the legality or propriety of the proceedings or order of the subordinate authority and to pass such order as he thinks fit. The width of this power is not confined to the particular ground on which the revisional proceedings were first set in motion. If the record discloses other questions touching legality or propriety, those questions may also be examined, whether they favour the revenue or the assessee. The revisional authority was therefore not justified in preventing the assessee from raising the other points decided against it by the appellate authority. The construction adopted is reinforced by the principle that suo motu revisional power is of wide amplitude.

Conclusion: The question was answered in the negative, in favour of the assessee and against the revenue.

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