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Issues: Whether the revisional power under Section 87 of the Rajasthan Sales Tax Act, 1994 could be exercised to reopen the assessment order without first calling for the assessment record, identifying specific error and prejudice to revenue, and affording adequate opportunity of hearing.
Analysis: The order permitting reopening was passed without the revisional authority first calling for the record of the assessing officer or recording any specific material showing how the earlier assessment was erroneous and prejudicial to the interests of revenue. The authority acted cursorily, on generalized allegations, and did not deal with the assessee's request for short adjournment to enable an effective reply to the notice. Exercise of revisional power requires satisfaction of the statutory preconditions and cannot rest on conjecture, haste, or non-specific grounds. The absence of particulars and the failure to afford adequate opportunity showed lack of application of mind and contravention of natural justice.
Conclusion: The revisional order was rightly set aside, and the challenge to that finding failed.