Revisional power under sales tax law extends beyond the assessment order to other records for omitted taxable turnover.

Section 32 confers special revisional power on the Deputy Commissioner to call for and examine an assessment order, make enquiry, and pass such order as warranted by the Act. The power is not confined to the face of the assessment order alone; the revisional authority may examine other relevant records to identify omissions in taxable turnover. An assessment can be erroneous by omission as well as by commission, and incomplete assessments may be corrected on the basis of extraneous material where necessary. The Deputy Commissioner was therefore competent to rely on other records, detect omitted inter-State sales, and revise the Central sales tax assessment.

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Issues: Whether the Deputy Commissioner, while exercising special revisional powers under section 32, could look beyond the assessment order and examine other records to detect an omission of taxable turnover and revise the Central sales tax assessment.

Analysis: Section 32 confers special revisional power on the Deputy Commissioner to call for and examine an assessment order, make such enquiry as he thinks fit, and pass such order as he thinks fit, subject to the Act. The provision does not restrict the revisional authority to the face of the assessment order alone. An assessment may be erroneous not only by commission but also by omission, and omissions of taxable turnover may not be discoverable from the assessment order itself. The power of revision is intended to rectify such incomplete assessments, and the use of relevant extraneous material for that purpose is not forbidden by the section.

Conclusion: The Deputy Commissioner was competent to rely on other records, detect the omission of inter-State sales from assessment, and revise the order under section 32.

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