Revisional jurisdiction limited to legal errors; factual findings on suppressed sales and turnover could not be disturbed.

Revisional jurisdiction under Section 24 of the Odisha Sales Tax Act, 1947 was confined to orders of the Tribunal under Section 23(3) and was not available to challenge appellate orders passed under Section 23(4)(c)(ii); the revision petitions were therefore held misdirected and not maintainable. On the merits, the Court declined to interfere with concurrent factual findings on suppression of sales, rejection of accounts, and reworking of taxable turnover because the conclusions rested on seized material, admissions, and evidentiary appreciation, and no perversity, irrelevant reliance, or error apparent was shown. The statutory orders were sustained and no revisional interference was warranted.

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Issues: (i) Whether a sales tax revision under Section 24 of the Odisha Sales Tax Act, 1947 was maintainable against an appellate order passed under Section 23(4)(c)(ii) of the Act. (ii) Whether the factual findings on suppression of sales, rejection of accounts, and reworking of taxable turnover called for interference in revision.

Issue (i): Whether a sales tax revision under Section 24 of the Odisha Sales Tax Act, 1947 was maintainable against an appellate order passed under Section 23(4)(c)(ii) of the Act.

Analysis: Section 23(4) creates a distinct statutory scheme for suo motu revision by the Commissioner or the delegated authority, with an appeal against an order passed in that jurisdiction lying under Section 23(4)(c). The revisional remedy under Section 24 is confined to orders of the Tribunal under Section 23(3) and not to appellate orders passed under Section 23(4)(c)(ii). The petitions were therefore misdirected in invoking revisional jurisdiction against the appellate orders.

Conclusion: The revision petitions were not maintainable to challenge the appellate orders under Section 23(4)(c)(ii).

Issue (ii): Whether the factual findings on suppression of sales, rejection of accounts, and reworking of taxable turnover called for interference in revision.

Analysis: The assessment and revisional authorities relied on seized material, admissions regarding substantial credit sales, failure to maintain proper sale and stock accounts, and the inadequacy of the disclosed turnover. The Court reiterated that each assessment year is a separate unit and that interference in revision is warranted only on a question of law or where a finding is perverse, unsupported by evidence, or based on irrelevant material. The challenge raised by the petitioner concerned factual appreciation already accepted by the appellate authority and did not disclose any perversity or error apparent on the face of the record.

Conclusion: The factual findings were affirmed and did not justify interference in revision.

Final Conclusion: The statutory authorities' orders were sustained, and no revisional interference was warranted on either maintainability or merits.

Ratio Decidendi: Revisional jurisdiction under Section 24 of the Odisha Sales Tax Act, 1947 lies only on a question of law and cannot be used to upset concurrent factual findings based on evidence in an appeal under Section 23(4)(c)(ii).

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