Revisional power under tax law is procedural, not a vested assessee right, so the amended jurisdiction applied.

Revision power under the Karnataka Sales Tax Act was treated as part of the statutory machinery for tax administration, not as a vested substantive right of the assessee. The text distinguishes procedural or machinery provisions from rights of appeal and states that the authorities on appellate rights were inapplicable. Because the assessment and revision notice were issued after the amendment conferring revisional power on the Joint Commissioner, the amended law governed the exercise of that power. The result stated in the text is that the Joint Commissioner was competent to invoke section 22-A and the challenge to the notice failed.

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Issues: Whether the Joint Commissioner had jurisdiction to invoke revisional power under section 22-A of the Karnataka Sales Tax Act in respect of an assessment relating to a period prior to the amendment, and whether such revisional power was a vested right of the assessee protected from later amendment.

Analysis: The assessment was completed and the revision notice was issued after the amendment conferring revisional power on the Joint Commissioner. The contention that the law prevailing on the date of the return governed the matter was tested against the distinction between substantive rights and procedural or machinery provisions. The authorities relied upon on the right of appeal were held to be inapplicable because the revisional power of the Commissioner or Joint Commissioner is not a vested right of the assessee but part of the statutory machinery for assessment administration. The scheme of the Act showed that the choice of assessing or revisional authority, and the time within which revision may be exercised, are matters of procedure, not rights accruing to the dealer.

Conclusion: The Joint Commissioner was competent to exercise revisional jurisdiction under section 22-A, and the challenge to the notice failed.

Final Conclusion: The writ petition was dismissed because the revisional amendment was treated as procedural and the notice issued by the Joint Commissioner was upheld.

Ratio Decidendi: A statutory power of revision conferred on a revenue authority is a matter of procedure and machinery for tax administration, not a vested substantive right of the assessee, and therefore may be exercised in accordance with the amended law.

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