Revisional jurisdiction cannot rely on post-assessment material; escaped assessment must proceed under the specific assessment provision.

Revisional jurisdiction under section 10-B of the U.P. Sales Tax Act, 1948 is confined to the legality or propriety of the assessment order on material already on the assessment record, and later-acquired information cannot be used to sustain revision. Where the case is really one of escaped assessment, proceedings must be taken under section 21 rather than by expanding revisional power. On the stated facts, additions based on a post-assessment income-tax search statement and other subsequent materials could not stand, while the addition relating to purchases of raddi from an unregistered dealer was supportable on the existing record.

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Issues: Whether the revisional authority under section 10-B of the U.P. Sales Tax Act, 1948 could revise the assessment order on the basis of materials that came into existence after the assessment order, and whether the additions made on that basis were sustainable.

Analysis: The revisional power under section 10-B is confined to examining the legality or propriety of the order on the basis of the material already available on the assessment record. Subsequent information or materials cannot be treated as the foundation for revision under that provision. If the case is one of escaped assessment, the proper course lies under section 21 and not by stretching revisional jurisdiction under section 10-B. On the facts, the additions founded on the income-tax search statement and other post-assessment materials could not stand. However, the assessment record showed that tax had not been imposed on the purchases of raddi from an unregistered dealer, and that part of the revisional addition was supportable.

Conclusion: The revision could not be sustained to the extent it rested on subsequent materials, but the addition relating to raddi was upheld.

Ratio Decidendi: Revisional jurisdiction under section 10-B of the U.P. Sales Tax Act, 1948 must be exercised only on the basis of material already on the assessment record, and subsequent materials cannot be used to justify revision; escaped assessment, if any, must be proceeded with under the specific assessment provision.

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