Revisional interference in sales tax requires illegality or impropriety; a different view of facts alone is insufficient.

Revisional interference under sales tax law is permissible only when the assessment order is shown to suffer from illegality or impropriety. Where no material was produced before the assessing authority to support a claim that disputed receipts arose from works contracts or to justify reduction of the profit rate, the revisional authority could not disturb the assessment merely because it preferred a different factual view. It also could not substitute its own conclusion for that of the assessing authority in the absence of supporting material. The assessment relief was therefore not sustained, and the revisional order was upheld.

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Issues: Whether the revisional authority could interfere with the assessment and grant relief in the absence of material showing illegality or impropriety in the assessment order, and whether it could substitute its own judgment for that of the assessing authority.

Analysis: The revisional power under the sales tax law is attracted only where the order sought to be revised suffers from illegality or impropriety. On the record, no material had been placed before the assessing authority to support the claim that the disputed receipts arose from works contracts or to justify reduction of the profit rate. In such circumstances, the revisional authority was not justified in disturbing the assessment merely on a different view of the facts, nor could it replace the assessing authority's conclusion with its own in the absence of relevant material.

Conclusion: The revisional authority had no basis to interfere, and its order setting aside the assessment relief was upheld. The appeal was dismissed.

Ratio Decidendi: Revisional interference is permissible only when the original order is shown to suffer from illegality or impropriety, and the revisional authority cannot substitute its own judgment for that of the assessing authority without supporting material.

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