Revisional jurisdiction limited to original assessment record; later material must be dealt with through reassessment proceedings.

Revisional jurisdiction under section 21(1) of the Punjab General Sales Tax Act is confined to the record that was before the Assessing Authority when the original assessment was made, and cannot be exercised on later-collected material or information received after assessment. Where fresh material arises after the assessment, the proper course is reassessment under section 11-A. On the stated facts, a definite finding could not be made that the impugned material was gathered only after the assessment, so the revisional authority was directed to act according to law and rely only on material forming part of the original assessment record.

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Issues: Whether proceedings under section 21(1) of the Punjab General Sales Tax Act could be sustained on the basis of material not available before the Assessing Authority when the original assessment order was passed, or whether such fresh material could only justify reassessment under section 11-A of the Act.

Analysis: The revisional power under section 21(1) is confined to examining the record that was before the Assessing Authority at the time of the original assessment and cannot be exercised on the basis of subsequently collected material or later received information. If fresh material comes into existence after the assessment, the proper course is initiation of reassessment proceedings under section 11-A. On the facts, however, it was not possible to record a definite finding that the impugned material had been collected only after the assessment order was made, so the revisional authority was directed to proceed according to law and not to rely on material that was not on the record when the assessment was passed.

Conclusion: Proceedings under section 21(1) could not proceed on fresh material outside the original assessment record, and the authority was required to confine itself to lawful material and, if appropriate, proceed under section 11-A.

Final Conclusion: The writ petitions were disposed of with a direction limiting the revisional authority to the material on the original record and leaving reassessment open in accordance with law.

Ratio Decidendi: Revisional jurisdiction cannot be used to reopen an assessment on the basis of material not before the assessing authority, and such later material, if relevant, must be dealt with through reassessment proceedings under the appropriate provision.

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