Revisional power and binding Supreme Court law justified reopening a paddy purchase-tax exemption after the commodity classification changed.

Revisional notices to reopen an assessment and withdraw a purchase-tax exemption on paddy were upheld as legally sustainable because later Supreme Court authority had clarified that paddy and rice are distinct commodities in ordinary commercial parlance and that dehusking or milling amounts to manufacture. That binding law provided a valid basis for revisional action even though an earlier High Court view had supported the exemption, and the authority was not required to wait for reversal of the prior view before acting. The challenge failed, and the notices were sustained against the assessee.

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Issues: Whether the revisional notices issued to reopen the assessment and withdraw the earlier exemption from purchase tax on paddy were sustainable in law.

Analysis: The earlier exemption had been granted on the basis of the then-prevailing view that paddy and rice were the same commodity and that milling did not amount to manufacture. The later Supreme Court decisions held that paddy and rice are distinct commodities in ordinary commercial parlance, that dehusking or milling effects a change in identity, and that the process involves manufacture. Those rulings supplied a valid legal basis for the authority to revisit the earlier assessment orders under the revisional provision, and the authority was not required to wait for the earlier High Court view to be reversed before acting on the binding Supreme Court law.

Conclusion: The revisional notices were valid and sustainable; the challenge failed and was against the assessee.

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