Revisional jurisdiction under entry tax law permits remand for recomputation, but not direct reassessment by the revisional authority.

Section 15(2) of the Karnataka Tax on Entry of Goods Act, 1979 confers distinct revisional powers on the Commissioner, Additional Commissioner, and Joint Commissioner, and the Additional Commissioner may revise orders of a Joint Commissioner or an appellate authority of Deputy Commissioner rank. An order made without jurisdiction is a nullity, so the jurisdictional objection could be raised at the appellate stage. The Additional Commissioner did not usurp the assessing authority's function: he set aside the appellate order only on the RS Emulsion issue and directed the assessing authority to recompute turnover and tax liability. That direction fell within revisional power, because the restriction is against the revisional authority itself undertaking reassessment, not against remitting the matter for fresh consideration.

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Issues: Whether the Additional Commissioner had jurisdiction under Section 15(2) of the Karnataka Tax on Entry of Goods Act, 1979 to revise the appellate order and direct recomputation of turnover and tax liability in respect of the RS Emulsion issue.

Analysis: Section 15 of the Act confers distinct revisional powers on the Commissioner, Additional Commissioner, and Joint Commissioner, with the Additional Commissioner empowered to revise orders passed by a Joint Commissioner or an appellate authority of the rank of Deputy Commissioner. The jurisdictional objection could be raised at the appellate stage because an order passed without jurisdiction is a nullity. The impugned order did not amount to the Additional Commissioner usurping the role of the assessing authority. It set aside the appellate order only on the RS Emulsion issue and directed the assessing authority to recompute the turnover and tax liability, which is within the permissible ambit of revisional power. The authorities relied upon by the assessee did not assist because they prohibit the revisional authority from itself undertaking reassessment, but do not forbid a direction for fresh consideration by the assessing authority.

Conclusion: The Additional Commissioner acted within jurisdiction under Section 15(2) of the Karnataka Tax on Entry of Goods Act, 1979, and the challenge to the revisional order failed.

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