Refund verification and reassessment upheld where no jurisdictional illegality or statutory breach was shown.

Verification of a refund claim was treated as within the assessing authority's authorised scope, and the subsequent reassessment was upheld where irregularities emerged in the deduction claims and the invoices did not separately disclose tax collection. The revisional court found no patent error, no breach of any statutory provision, and no jurisdictional illegality in the verification leading to reassessment. It also declined to disturb concurrent factual findings recorded by the lower authorities, with the Revenue's position sustained.

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Issues: Whether the assessing authority lacked jurisdiction to verify the refund claim and to proceed with re-assessment in the absence of a specific authorisation, and whether the reassessment and disallowance of deductions suffered from any illegality warranting interference in revision.

Analysis: The order of the Commissioner was read as authorising verification of the refund claim and also as vesting power for assessment and re-assessment in eligible cases. The authority, while verifying the books of account to test the refund claim, noticed irregularities in the manner of claiming deductions and in the absence of separate disclosure of tax collection in individual invoices. The revisional court found no patent error, no demonstrated violation of any statutory provision, and no jurisdictional illegality in the manner in which the verification led to reassessment. It also declined to re-open concurrent factual findings recorded by the lower authorities.

Conclusion: The challenge to the reassessment and the consequential orders was rejected, and the finding on the Revenue's favour was sustained.

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