Suo motu revision requires an erroneous and prejudicial assessment; reassessment based on conjecture was quashed.

Suo motu revision under section 20(1) of the Assam Finance (Sales Tax) Act, 1956 is supervisory and can be used only where the completed assessment is both erroneous and prejudicial to the interests of Revenue. A mere belief that turnover was understated is insufficient; the revisional authority must rely on materials already on record and show how the original assessment involved an error of law or jurisdiction. Reopening based only on an inspector's report, without authentic supporting material or independent application of mind, is based on conjecture and extraneous direction. The revisional order and the consequential reassessment orders were therefore held unsustainable and quashed.

---

---

Issues: Whether the revisional authority could invoke suo motu revision under section 20(1) of the Assam Finance (Sales Tax) Act, 1956 to reopen completed assessments and redetermine turnover without showing that the original assessments were erroneous and prejudicial to the interests of Revenue.

Analysis: The power of suo motu revision is supervisory in nature and can be exercised only when the assessment order is both erroneous and prejudicial to the interests of Revenue. A mere view that the turnover was low or under-assessed is not enough. The revisional authority must base its satisfaction on materials already on record and must record how the original assessment suffered from error of law or jurisdiction. Reassessment founded on an inspector's report, without authentic supporting material or any finding that the earlier assessments were unsustainable in law, amounts to acting on conjectures, surmises, and extraneous directions rather than on independent application of mind.

Conclusion: The revisional order under section 20(1) was not legally sustainable, and the consequential reassessment orders were also invalid; both were quashed.

---