Revisional power cannot reopen an assessment on material already on record when the original authority simply failed to apply its mind.

Revisional power under section 14(4) of the Andhra Pradesh General Sales Tax Act, 1957 cannot be used to withdraw exemption merely because the assessing authority later noticed a defect in F forms that were already on record. The original assessment had accepted the forms and treated the transactions as consignment sales; the alleged defect was not discovered from new material, but from the same material available at the first assessment. A failure to apply mind to existing record, or lack of diligence, does not justify revision. On that basis, the revised assessment orders were unsustainable and were quashed.

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Issues: Whether revised assessment orders could be made under section 14(4) of the Andhra Pradesh General Sales Tax Act, 1957 to withdraw exemption earlier granted on F forms already on record but found to cover periods exceeding one calendar month.

Analysis: The initial assessment had accepted the F forms and granted exemption on the turnover treating the transactions as consignment sales. The alleged defect in the F forms was not based on material discovered later from outside the record, but on the same material that was before the assessing authority when the original assessment was made. The governing principle is that section 14(4) cannot be invoked merely because the assessing authority failed to advert to material already on record; such non-application of mind or lack of diligence does not furnish a valid ground for revision. Since the revised orders were founded on the very material considered at the original assessment stage, the power of revision was improperly exercised.

Conclusion: The revised assessment orders were unsustainable and were rightly quashed.

Final Conclusion: The writ petitions succeeded and the attempted reassessment was invalid because the statutory revisional power could not be used to correct an omission in the original assessment based on material already available to the assessing authority.

Ratio Decidendi: Revisional power cannot be exercised to reopen an assessment on the basis of material already on record when the original authority merely failed to apply its mind to that material.

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