Revisional withdrawal of an acted-upon tax exemption certificate was unjustified where completed assessments would be reopened unfairly.

Revisional power should not be used to withdraw an eligibility certificate for an unexpired period after it was duly granted, acted upon, and followed by completed assessments. Where the authority had already accepted the statutory conditions and the later suo motu revision was based only on an alleged error of law, interference after a substantial lapse of time would reopen concluded assessments, create fresh liability for a period already treated as exempt, and work unfair prejudice. On these special facts, the Tribunal found the revisional interference unjustified and set aside the impugned order in favour of the assessee.

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Issues: Whether the suo motu revisional order withdrawing the already granted eligibility certificate for the unexpired period should be sustained.

Analysis: The exemption had been granted by the competent authority after satisfaction of the statutory conditions, and assessments had already been completed on that basis. The revisional order was passed after a substantial lapse of time on the footing of an alleged error of law in the grant of the certificate. In the special facts, the withdrawal would reopen concluded assessments and impose fresh liability on the assessee for a period during which tax had not been collected. The Tribunal held that such interference was unjust and contrary to fair play.

Conclusion: The suo motu revision was not justified and the impugned order was set aside in favour of the assessee.

Final Conclusion: The application succeeded and the revisional interference with the eligibility certificate was annulled.

Ratio Decidendi: A revisional power should not be exercised to withdraw a tax exemption already granted and acted upon, where such interference would disturb completed assessments and cause unfair prejudice to the assessee without compelling justification.

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