Revisional jurisdiction over gift-tax valuation fails where the assessment reflects application of mind and considered valuation materials.

Revisional jurisdiction under section 24(2) required the assessment order to be both erroneous and prejudicial to the Revenue. The Gift-tax Officer had examined the balance-sheet, considered valuation materials, and applied an appropriate valuation method for the gifted shares, so the assessments were not cryptic or made without application of mind. On those facts, the Commissioner could not invoke revision merely to substitute a different valuation approach, and the revisional proceedings were held liable to be quashed.

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Issues: Whether the Commissioner could invoke revisional jurisdiction to set aside the gift-tax assessments on the ground that the Gift-tax Officer had wrongly valued the gifted shares and had not made proper enquiry.

Analysis: The assessment orders showed that the Gift-tax Officer examined the balance-sheet, considered the valuation material and applied the relevant valuation approach for the gifted shares. The Court found that the assessments were not cryptic or passed without application of mind. It further held that revisional power under section 24(2) could be exercised only when the assessment order was both erroneous and prejudicial to the interests of the Revenue, and those conditions were not satisfied on the facts. The Commissioner's attempt to substitute a different valuation approach did not justify revision where the original assessments were made after consideration of the relevant materials.

Conclusion: The Commissioner lacked jurisdiction to initiate revision under section 24(2), and the revisional proceedings and order were liable to be quashed.

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