Suo motu revision can be prompted by assessee-supplied information, but no enforceable right to revision arises.

An assessee may place relevant material before the Commissioner, but this does not create an enforceable right to revision. Section 21 authorises suo motu revision where the Commissioner, on examining information from any source, including the assessee, considers that the subordinate proceedings may be illegal or improper. The decisive point is that the Commissioner must act on his own motion, not at the instance of a party as of right. Accordingly, the filing of an application by the assessee does not exclude the case from section 21, and the Commissioner may lawfully proceed if the information justifies action.

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Issues: Whether the assessee could bring relevant information to the notice of the Commissioner for exercise of suo motu revision under section 21 of the Punjab General Sales Tax Act, 1948, and whether the Commissioner could act on such information.

Analysis: Section 21 empowered the Commissioner to call for records and examine the legality or propriety of proceedings of subordinate authorities of his own motion. The power was not converted into a statutory right of revision in favour of the assessee, but the source of information that prompted the Commissioner to consider action was not confined to the department. Relevant information could be supplied by any person, including the assessee, and if the Commissioner considered that the information disclosed illegality or impropriety, he could still proceed of his own motion. The assessee could not compel the Commissioner to act, but the filing of an application by the assessee did not by itself take the case outside the scope of section 21.

Conclusion: The assessee was entitled to place relevant information before the Commissioner, and the Commissioner could lawfully initiate suo motu revision on that basis if he chose to do so.

Final Conclusion: The reference was answered by holding that an assessee may notify the Commissioner of relevant material, though no enforceable right to revision is created, and the Commissioner may proceed on his own motion if the information warrants action.

Ratio Decidendi: A suo motu revisional power may be triggered by information from any source, including an assessee, so long as the authority acts on its own motion and not at the instance of a party as of right.

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