Revisional power under sales tax law may extend to remand for fresh enquiry when the record shows incomplete assessment and unmet burden of proof.

Section 21 of the Karnataka Sales Tax Act confers wide revisional power to test the legality, propriety and regularity of assessment orders, and that power is not curtailed by the separate escaped-turnover mechanism under section 12-A because the provisions operate in different fields. Where the record shows incomplete enquiry, failure to probe a relevant claim, or objective discrepancies in declarations and purchase figures, the revisional authority may direct further enquiry and remand the matter. The assessee continued to bear the burden of proving exemption or second-dealer status under section 6-A, and form 32 was not indispensable if other satisfactory evidence was produced.

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Issues: Whether the revisional authority under section 21 of the Karnataka Sales Tax Act, 1957 could interfere with assessment orders and remand the matters for further enquiry on the basis of discrepancies appearing in the record, notwithstanding the availability of proceedings for escaped turnover under section 12-A.

Analysis: Section 21 confers a wide supervisory power to examine the legality or propriety of an assessment order or the regularity of proceedings, but the power must rest on objective material appearing from the record and not on mere suspicion. The existence of a separate power under section 12-A does not curtail section 21, because the two provisions operate in different fields. If the record reveals that the assessing authority failed to probe a relevant claim, or that the enquiry was incomplete, the revisional authority may direct further enquiry and remand the matter. The burden to establish exemption or second-dealer status remained on the assessee under section 6-A, and the absence of satisfactory material, including the mismatch in the relevant declarations and purchase figures, justified revisional interference. Production of form 32 was not mandatory in every case, but other acceptable evidence was still required to discharge the burden.

Conclusion: The revisional authority acted within jurisdiction in setting aside the assessments to the limited extent necessary for fresh enquiry, and the challenge to the remand orders failed.

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