Revisional jurisdiction on existing assessment record is distinct from escaped-assessment reopening, so the shorter limitation did not apply.

Revision on the existing assessment record remained distinct from reopening an escaped assessment, because the former tests legality, propriety, or regularity on material already on record, while the latter requires fresh material or information showing escaped or under-assessed turnover. The Deputy Commissioner acted under revisional power and merely corrected the tax rate on the same record; that did not convert the action into escaped-assessment proceedings. The shorter limitation for escaped assessments therefore did not apply, and the revisional order was within the limitation period for revision.

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Issues: Whether the Deputy Commissioner's order revising the assessment by restoring the tax rate to the correct rate was one made under revisional power, or one made in respect of escaped assessment so as to attract the shorter limitation period.

Analysis: The power of revision under section 20 and the power to reopen an escaped assessment under section 14(4) operate in different fields. Revision under section 20 is exercised on the material already on record to test the legality, propriety, or regularity of the assessment order, whereas section 14(4) is attracted when, on fresh material or information, turnover has escaped assessment, been under-assessed, or assessed at a lower rate. The Deputy Commissioner acted avowedly under section 20 and only on the same assessment record. The correction of the rate of tax by itself did not convert the action into one under section 14(4). The limitation in section 14(4-A) therefore had no application, and the revisional order was within the limitation prescribed by section 20(3).

Conclusion: The limitation plea failed, and the revisional order was held to be valid under section 20.

Ratio Decidendi: A revision on the existing assessment record falls within revisional jurisdiction and is distinct from reopening of escaped assessment, which requires fresh material or information.

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