Suo motu revision may follow a later legal ruling where no fresh facts emerge, and reassessment limits do not apply.

A later judicial declaration of the correct legal position, without fresh factual material or suppressed turnover on the assessment record, can justify suo motu revision under section 21 of the Punjab General Sales Tax Act, 1948. Section 11-A applies to reassessment based on definite information showing under-assessment or escaped assessment within the prescribed period, but it was not attracted here because the revisional authority relied only on the subsequent legal interpretation, not new facts. The revisional notice and proceedings were therefore sustained, and the challenge to revision failed.

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Issues: Whether the revisional authority could invoke suo motu revision under section 21 of the Punjab General Sales Tax Act, 1948 on the basis of a later judicial pronouncement, or whether the matter was confined to reassessment under section 11-A of that Act and barred by limitation.

Analysis: The reassessment provision under section 11-A applies where the Assessing Authority proceeds on definite information showing under-assessment or escaped assessment within the prescribed period. Here, the revisional authority did not act on fresh factual material relating to suppressed turnover; it only received the correct legal position from a later decision of the High Court. The assessment orders had already been passed on the existing record, and the subsequent judicial interpretation did not introduce new facts. Section 21 confers revisional power to examine the legality or propriety of orders of subordinate authorities, and that power is not confined by the limitation applicable to reassessment where no new material is brought in.

Conclusion: Section 11-A was not attracted. The revisional authority validly exercised suo motu power under section 21, and the challenge to the revisional notice and proceedings failed.

Final Conclusion: The petition was rejected, and the revisional authority was left free to proceed with the revision in accordance with law.

Ratio Decidendi: A later judicial declaration of the correct legal position, without any fresh factual material not already on the assessment record, may support suo motu revision under the revisional provision; it does not convert the matter into reassessment governed by the limitation for escaped assessment.

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