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Issues: Whether the revenue could invoke revisional jurisdiction under section 20(3) of the Bengal Finance (Sales Tax) Act, 1941, to enhance turnover when the case was one of under-assessment or escaped assessment for which reassessment under section 11-A was the proper remedy.
Analysis: Section 11-A specifically empowers reassessment where, on definite information, turnover has escaped assessment or been under-assessed, but only within the prescribed limitation period. Section 20(3) is a separate revisional power meant to correct errors apparent in the assessment made on the material before the assessing authority. Where the assessing authority lacked information or material and the omission resulted in escaped assessment or under-assessment, the proper course is reassessment under section 11-A and not revision under section 20(3). Revision cannot be used to bypass the limitation attached to reassessment.
Conclusion: The revisional authority had no jurisdiction under section 20(3) on the facts, and the matter was one for reassessment under section 11-A.
Ratio Decidendi: Revisional power cannot be used to tax escaped or under-assessed turnover in circumstances that properly attract reassessment, especially where the reassessment period has expired; revision is confined to correcting errors within the record before the assessing authority.