Revisional review limited to questions of law: unraised PDS exemption claim could not be entertained.

Revision under the U.P. Value Added Tax Act, 2008 was confined to questions of law arising from the Tribunal's order, so a new issue not raised or canvassed before the appellate authorities could not be examined. The assessee failed to produce material showing that the disputed wheat, rice and related transactions were confined to PDS supplies, and the controversy before the statutory authorities remained centred on rate and valuation. The claimed PDS exemption therefore could not be entertained in revision, because a question neither raised before the Tribunal nor dealt with by it does not arise for revisional consideration.

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Issues: Whether the revision could succeed on a question of law that was not raised or canvassed before the appellate authorities, and whether the claimed exemption for supplies under the PDS scheme could be accepted in revision.

Analysis: The assessment under the U.P. Value Added Tax Act, 2008 proceeded on the basis of discrepancies in the accounts and the nature of transactions in wheat, rice and other food items. The authorities found that the revisionist had not produced material to show that the disputed transactions were confined to PDS supplies, and the controversy before the statutory authorities was in substance confined to the rate and valuation of wheat and rice. In revision under Section 11 of the Trade Tax Act, the High Court could interfere only on a question of law arising from the Tribunal's order. A question neither raised before the Tribunal nor dealt with by it does not arise from the order for revisional consideration.

Conclusion: The PDS exemption issue did not arise for consideration in revision, and the challenge failed for want of a permissible question of law.

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