Revisional power is confined to the challenged assessment and cannot reopen a final compounding order.

Turnover from purchases of jewellery material was treated as taxable under section 7-A of the Tamil Nadu General Sales Tax Act, following the reasoning applied in the connected matter. The revisional authority could not disturb an earlier final order granting compounding under section 7(1) or aggregate that turnover with the later assessment, because its power was confined to the assessment lawfully under challenge. The earlier compounding order had attained finality and could not be reopened after the statutory period. The result was that tax under section 7-A was upheld, while the assessee retained the benefit of compounding for the earlier order.

---

---

Issues: (i) whether the turnover of Rs. 30,637.50 was liable to tax under section 7-A of the Tamil Nadu General Sales Tax Act; (ii) whether the Board of Revenue could, in revision, disturb the earlier order dated 27 November 1970 granting the assessee the benefit of compounding under section 7(1) and aggregate that turnover with the later assessment.

Issue (i): whether the turnover of Rs. 30,637.50 was liable to tax under section 7-A of the Tamil Nadu General Sales Tax Act.

Analysis: The turnover arose from purchases of jewellery material and the liability under section 7-A was specifically the subject of the later assessment order. The contention that section 7-A was inapplicable was rejected in view of the governing reasoning applied in the connected matter decided on the same day.

Conclusion: The turnover of Rs. 30,637.50 was held taxable under section 7-A, against the assessee.

Issue (ii): whether the Board of Revenue could, in revision, disturb the earlier order dated 27 November 1970 granting the assessee the benefit of compounding under section 7(1) and aggregate that turnover with the later assessment.

Analysis: The assessment was split into two distinct orders, one under section 7(1) and the other under section 7-A. The revision was competent only in relation to the appellate order arising from the later assessment, and the earlier order had already attained finality. The Board could not, after the statutory period, reopen the earlier compounding order or enlarge the revision so as to upset that finality.

Conclusion: The Board's order was held unsustainable to the extent it disturbed the earlier compounding order and aggregated the turnovers, and the assessee retained the benefit of compounding for the year.

Final Conclusion: The decision upheld the levy under section 7-A but confined the revisional power so that the earlier compounding order remained undisturbed, resulting in only partial relief to the assessee.

Ratio Decidendi: A revisional authority cannot, by an order within time against one assessment, indirectly reopen an earlier order that has attained finality and is beyond the period of revision; the revisional power must remain confined to the order lawfully under challenge.

---