Revisional power cannot override a reasoned appellate finding without addressing material facts and objections.

A reasoned appellate order finding no suppression of sales or purchases and rejecting estimated turnover could not be displaced through suo motu revision without a clear showing that the order was legally or factually unsustainable. The revisional authority was required to address the assessee's objections and the factual basis of the appellate conclusion, including regular sales records and the absence of suppression, before interfering. A summary or casual exercise of revisional power, without meeting those findings, was unsustainable. The HC therefore reinstated the appellate order and the assessee obtained relief from the revised assessment.

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Issues: Whether the revisional authority was justified in invoking suo motu revision to restore the assessment when the first appellate authority had found no suppression of sales or purchases and had given reasons for rejecting the estimated turnover.

Analysis: The appellate authority had recorded a factual finding that the assessee maintained regular sales records, that the inspection dates were exceptional trading days, and that no purchase or sales suppression was established. The revisional authority did not disturb that core finding and did not give reasons showing why the appellate order was erroneous or why the appellate discretion had been wrongly exercised. In a revision of this nature, interference is warranted only when the appellate order is shown to be legally or factually unsustainable, and the revisional authority must address the objections raised and the basis of the appellate conclusion. A casual or summary exercise of revisional power, without meeting the material findings of the first appellate authority, is not sustainable.

Conclusion: The suo motu revision was not justified and the order restoring the assessment could not stand.

Final Conclusion: The appellate authority's order was reinstated and the assessee obtained relief from the revised assessment.

Ratio Decidendi: Revisional power cannot be exercised to displace a reasoned appellate order unless the appellate findings are shown to be erroneous, and the revisional authority must independently deal with the material objections and factual conclusions before interfering.

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