Limited revisional jurisdiction barred conversion of revision into appeal, but belated writ interference was refused as academic.

The Board of Revenue was found to have exceeded its limited revisional jurisdiction under the Rajasthan Sales Tax Act by directing that a revision be treated as an appeal before the Deputy Commissioner (Appeals). However, because the assessee's appeal and the matter treated as an appeal had already been disposed of, and a further revision was pending, the Court declined to exercise writ jurisdiction under Article 226 at such a belated stage. It held that interference would serve no useful purpose, would only create an academic result, and could complicate rather than resolve the dispute.

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Issues: Whether, in view of the belated stage and the subsequent procedural developments, the Court should exercise writ jurisdiction under Article 226 to quash the Board of Revenue's order treating a revision as an appeal.

Analysis: The Court found that the Board of Revenue had acted beyond its limited revisional jurisdiction under the Rajasthan Sales Tax Act when it directed that the revision be treated as an appeal before the Deputy Commissioner (Appeals). However, it also noted that the assessee's appeal and the matter sent down as an appeal had already been disposed of, and a further revision was pending before the Board of Revenue. In these circumstances, the Court held that interference at such a belated stage would serve no useful purpose, would only produce an academic result, and could complicate rather than resolve the dispute.

Conclusion: The writ jurisdiction was not invoked, and the writ petition was dismissed.

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