Revisional power and reassessment operate separately; limitation for escaped turnover reassessment does not control supervisory revision.

The Kerala High Court explained that revisional power under section 35 of the Kerala General Sales Tax Act, 1963 operates independently of reassessment under section 19. Section 35 is meant to correct illegality, irregularity or impropriety in the order under revision, and it is not excluded merely because the issue also involves escaped turnover. The limitation period applicable to reassessment under section 19 does not control supervisory revision under section 35, because each provision operates in a different field and is subject to its own time-limit and conditions. The challenge based on escaped turnover and limitation therefore failed.

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Issues: Whether the Deputy Commissioner could invoke revisional power under section 35 of the Kerala General Sales Tax Act, 1963 to reach escaped turnover and whether that power was controlled by the limitation prescribed for reassessment under section 19 of the Act.

Analysis: The revisional power under section 35 and the reassessment power under section 19 operate in different fields and are vested in different authorities. The revisional jurisdiction is meant to correct illegality, irregularity or impropriety in the order under revision, and it is not barred merely because the matter also concerns escaped turnover. The limitation applicable to reassessment under section 19 does not govern the exercise of supervisory revision under section 35, which has its own time-limit and conditions.

Conclusion: The Deputy Commissioner was competent to proceed under section 35, and the challenge based on exclusion of escaped turnover and limitation failed.

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