Revisional jurisdiction cannot target an order rendered inoperative once reassessment proceedings have been validly initiated.

Once reassessment proceedings are validly initiated, the earlier assessment order ceases to remain operative for further revision. On the stated facts, notices had already been issued under Section 39(2)(e) of the Karnataka Value Added Tax Act, 2003 for the same tax periods, so the prior order no longer survived in law for revisional scrutiny under Section 63-A(1). Revisional jurisdiction could not, therefore, be exercised against an order that had already been rendered inoperative by the reassessment process. The proper course was to permit the reassessment to proceed and be concluded by the assessing authority, and the revisional orders were without jurisdiction.

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Issues: Whether the revisional authority could invoke revisional jurisdiction under Section 63-A(1) of the Karnataka Value Added Tax Act, 2003 to revise an order already rendered inoperative upon initiation of reassessment proceedings under Section 39(2)(e) of the Act.

Analysis: The relevant principle is that once reassessment proceedings are validly initiated, the earlier assessment or reassessment order ceases to be operative and is treated as having been set aside for the purpose of further action. On the facts, notices under Section 39(2)(e) had already been issued for the same tax periods, which meant that the earlier order dated 16.08.2014 no longer survived for revision. Revisional jurisdiction could not, therefore, be exercised against an order that had ceased to exist in law. The proper course was to allow the reassessment proceedings to continue and be concluded by the assessing authority.

Conclusion: The invocation of revisional power was without jurisdiction and the impugned revisional orders were liable to be quashed.

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