Revisional jurisdiction cannot be exercised twice over the same subject-matter once validly invoked under sales tax law.

Revisional power under section 67(1)(a) of the Gujarat Sales Tax Act, 1969, when validly exercised by an officer empowered under section 27, exhausts jurisdiction over that subject-matter. Here, the Assistant Commissioner had already exercised that revisional power for the same matter, so a later notice by the Deputy Commissioner amounted to a second exercise of the same jurisdiction and was not permitted. The court held that the notice was issued without jurisdiction and was therefore null and void. The preliminary objection of prematurity failed because the challenge went to the authority to issue the notice itself.

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Issues: Whether a Deputy Commissioner could invoke suo motu revisional power under section 67(1)(a) of the Gujarat Sales Tax Act, 1969 to revise an order on the same subject-matter after an Assistant Commissioner had already exercised revisional power under the same provision.

Analysis: Revisional power under section 67(1)(a) vested in the Commissioner and could be exercised through officers empowered under section 27. When the Assistant Commissioner earlier exercised that power in respect of the same subject-matter, he did so as the Commissioner for that purpose, and the revisional jurisdiction stood exhausted. The later notice issued by the Deputy Commissioner was therefore an attempt to re-exercise the same revisional power over the same matter, which the Act did not permit. The preliminary objection of prematurity failed because the challenge went to the very jurisdiction to issue the notice.

Conclusion: The impugned notice was without jurisdiction, null and void, and liable to be quashed.

Ratio Decidendi: Once revisional jurisdiction under section 67(1)(a) is validly exercised in respect of a particular subject-matter, it cannot be invoked again by another officer acting under the same statutory authority for the same subject-matter.

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