Revisional power over assessment allows withdrawal of wrong exemption and refixation of taxable turnover within existing records.

Section 32 of the Tamil Nadu General Sales Tax Act, 1959 was construed as conferring revisional power wide enough to modify an assessment and refix taxable turnover by cancelling an exemption wrongly granted by the assessing authority. The Court treated this as a correction within the existing turnover, not a fresh assessment on escaped turnover under the specific escaped-assessment provision. Because no new turnover was introduced and the authority merely withdrew an erroneous exemption, the power to pass such order as it thought fit was held to include the ancillary power to revise the assessment in this manner.

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Issues: Whether the revisional authority under section 32 of the Tamil Nadu General Sales Tax Act, 1959, had power to modify the assessment order and refix the taxable turnover by cancelling an exemption wrongly granted by the assessing authority.

Analysis: The revisional power under section 32, both before and after amendment, was construed as wide enough to enable the authority to pass such order as it thought fit, subject to the Act and without making an assessment on escaped turnover under the specific escaped-assessment provision. The case before the Court involved no new turnover being introduced; the revisional authority merely withdrew an exemption wrongly allowed on the existing turnover. The reliance placed on cases dealing with fresh determination of turnover or inclusion of turnover not before the assessing authority was held inapplicable. The Court also noted that the phrase empowering the authority to pass such order as it thought fit had been judicially understood as conferring all ancillary powers except enhancement, and that modifying the assessment by refixing turnover after disallowing the erroneous exemption fell within that power.

Conclusion: The revisional authority had the power to modify the assessment order and refix the taxable turnover by cancelling the wrongly granted exemption, and the assessee's challenge failed.

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