Suo motu revisional power must rest on relevant material, and mechanical interference with a reasoned appellate order is impermissible.

Suo motu revisional jurisdiction under the Tamil Nadu General Sales Tax Act, 1959 must be exercised only on relevant material and with proper consideration of the appellate order. The Appellate Assistant Commissioner had examined the seized slips and accounts and reduced the suppression estimate on a reasoned appraisal, while the revisional authority failed to identify any specific error or material justifying restoration of the original assessment. A casual or mechanical interference was therefore impermissible, and the revisional order could not stand. The appellate relief was restored in favour of the assessee.

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Issues: Whether the revisional interference with the order of the Appellate Assistant Commissioner under the Tamil Nadu General Sales Tax Act, 1959 was justified on the facts, and whether the restored appellate order could stand.

Analysis: The Appellate Assistant Commissioner had examined the seized slips and the accounts and had brought down the suppression estimated by the assessing authority on a reasoned appraisal of the material. The revisional authority, while exercising suo motu powers, did not demonstrate any specific error in the appellate order or any material warranting restoration of the original assessment. Revisional power under the Act is not to be exercised casually or mechanically, but only where interference is justified on relevant material and with due application of mind.

Conclusion: The revisional order was unsustainable and the order of the Appellate Assistant Commissioner was rightly restored. The issue is answered in favour of the assessee.

Final Conclusion: The appeal succeeds and the assessee obtains restoration of the appellate relief against the revisional enhancement.

Ratio Decidendi: Suo motu revisional jurisdiction under the Tamil Nadu General Sales Tax Act, 1959 can be invoked only on relevant material and after proper consideration of the appellate order; a casual or mechanical interference without demonstrating error or warranting material is impermissible.

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