Arithmetical error in tax demand can be corrected in revision, but new factual objections are barred at that stage.

A demonstrable arithmetical error in the tax demand could be corrected in revision, and the demand on brick purchases was reduced accordingly. However, a factual objection concerning assessment of different articles was not open at the revisional stage because it had not been raised before the appellate authorities. The demand was therefore corrected from Rs. 4,78,250/- to Rs. 47,825/- on brick purchases of Rs. 9,56,000/-, and the revisions were disposed of to that extent, with the remaining challenge left undisturbed by the HC.

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Issues: Whether the tax demand on purchase of bricks was liable to correction on account of a calculation mistake.

Analysis: The revisions survived only on the question of correctness of the demand computation. The challenge to the factual assessment of different articles was not available at the revisional stage since it had not been raised before the appellate authorities. On the brick purchase figure, the Standing Counsel accepted that the demand had been computed incorrectly and required correction.

Conclusion: The demand was corrected from Rs. 4,78,250/- to Rs. 47,825/- on purchase of bricks of Rs. 9,56,000/-, and the revisions were disposed of to that extent.

Final Conclusion: The outcome granted only limited relief by rectifying the tax demand, while leaving the remaining challenge undisturbed.

Ratio Decidendi: A demonstrable arithmetical mistake in assessment can be corrected in revision, but a factual objection not raised before the appellate authorities cannot be agitated at that stage.

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