Revisional jurisdiction under sales tax law survives where a later judgment clarifies the law without new factual material.

A later judicial pronouncement clarifying the correct interpretation of a taxing entry is not fresh information when no new factual material is relied upon beyond the assessment record. In that situation, the revising authority may validly proceed under section 21(1) of the Punjab General Sales Tax Act to examine the legality or propriety of the assessment, and section 11-A is not attracted. The principle applies where the judicial decision merely declares the law and does not introduce outside facts. On that basis, revisional action based on the existing record remains within jurisdiction and is not displaced by the plea of fresh information.

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Issues: Whether the revising authority could validly initiate and continue proceedings under section 21(1) of the Punjab General Sales Tax Act on the basis of an earlier judicial decision, or whether such material amounted to fresh information attracting section 11-A of the Act.

Analysis: The challenge was confined to the contention that the judgment of the Tribunal, as affirmed by the High Court, constituted fresh and definite information and therefore the matter could proceed only under section 11-A. The Court rejected this submission and followed the earlier view that the revising authority had not acted on any outside factual material. The judicial decision merely declared the correct legal position and related back to the date of the statute. Where no new facts or material outside the assessment record are relied upon, the revisional power under section 21(1) is not displaced by section 11-A. The Court approved the principle that the revising authority may examine the legality or propriety of the assessment on the basis of the existing record, though it cannot bring to tax matters requiring fresh material beyond that record.

Conclusion: The proceedings were rightly initiated under section 21(1) of the Punjab General Sales Tax Act and the objection based on section 11-A failed.

Final Conclusion: The writ petitions were dismissed because the revisional action was held to be within jurisdiction and not vitiated by the availability of fresh information.

Ratio Decidendi: A later judicial pronouncement declaring the correct interpretation of a taxing entry is not fresh information for purposes of revisional jurisdiction when no new factual material beyond the original assessment record is relied upon.

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