Revision based on existing material and beyond the statutory time limit could not be sustained under the APGST Act.

An assessment revised under section 14(4) of the APGST Act cannot be sustained where it rests only on material already on record and no fresh material is shown. The revisional authority under section 20(2) also failed to cure that foundational defect and, in any event, sought to revise the original assessment beyond the four-year limit prescribed under section 20(3). The Tribunal was therefore justified in interfering with the revisional order, even though its reasoning differed from the grounds ultimately accepted.

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Issues: Whether the assessment revised under section 14(4) of the APGST Act could stand when it was based only on existing material, and whether the revisional order under section 20(2) of the APGST Act was vitiated by limitation.

Analysis: The assessment order dated 21.04.2004 was made on material already on record and not on any fresh material. The earlier appellate order that had set aside that assessment was in line with the settled law of the Court that such a revision could not be sustained on existing material. The revisional authority, while invoking section 20(2), did not address this foundational defect and also sought to revise the original assessment long after the period of four years prescribed under section 20(3). In these circumstances, the Tribunal was justified in interfering with the revisional order, though for reasons different from those recorded by it.

Conclusion: The assessment revised under section 14(4) could not be sustained, and the revisional action under section 20(2) was also barred by limitation. The challenge to the Tribunal's order therefore failed.

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