Revisional power cannot replace a reasoned factual finding; interference requires perversity, illegality, or disregard of evidence.

Revisional interference with a reasoned appellate finding on alleged suppression of sales turnover is confined to cases of demonstrable perversity, illegality, disregard of relevant material, or patent misconstruction of evidence. Where the Appellate Assistant Commissioner has examined slips, accepted the assessee's explanation on facts, and recorded cogent reasons that they do not show undisclosed sales, the Joint Commissioner cannot invoke suo motu revision merely to substitute a different view. The revisional power is narrower than appellate power and must be exercised judicially. On that principle, the restoration of the reassessment and the related addition were set aside in favour of the assessee.

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Issues: Whether the Joint Commissioner was justified in exercising suo motu revisional power to interfere with the Appellate Assistant Commissioner's finding that the slips did not establish suppression of sales turnover.

Analysis: The appellate authority had examined the slips and accepted the assessee's explanation on facts, recording cogent reasons for holding that they did not represent undisclosed sales. Revisional interference with such a finding was permissible only if the appellate order was shown to be perverse, illegal, based on disregard of relevant material, or founded on patent misconstruction of evidence. A revisional authority cannot reassess the same facts merely because it prefers a different view or because the explanation does not satisfy it. The power under revision is narrower than appellate power and must be exercised judicially, not mechanically.

Conclusion: The suo motu revision was not justified, and the order restoring the reassessment was liable to be set aside in favour of the assessee.

Final Conclusion: The appellate authority's factual finding was restored, and the addition based on alleged suppression did not survive.

Ratio Decidendi: Revisional power cannot be used to substitute a mere change of opinion for a reasoned appellate finding of fact; interference is warranted only on demonstrable perversity, illegality, or disregard of relevant evidence.

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