Revisional power under entry tax law cannot extend to a Commercial Tax Officer's assessment order outside the statutory hierarchy.

The revisional power under Section 15 of the Karnataka Tax on Entry of Goods Act, 1979 is confined to the jurisdiction expressly conferred by the provision and by the hierarchy of authorities. An assessment order passed by the Commercial Tax Officer could not be revised where it lay outside that permissible revisional chain, and the phrase "any proceedings" was not treated as authorising such revision. The impugned revisional order therefore could not stand.

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Issues: Whether an assessment order passed by the Commercial Tax Officer could be revised under Section 15 of the Karnataka Tax on Entry of Goods Act, 1979.

Analysis: The revisional power under Section 15 is structured by the hierarchy of authorities and is confined to the jurisdiction expressly conferred by the provision. The prior decision relied upon had already explained that, although the revisional authority could validly exercise power over an order within its revisional chain, it could not extend that power to set aside a subsequent assessment order passed by the assessing authority when such order lay outside the permissible scope of revision. The expression 'any proceedings' was therefore not accepted as authorising revision of the Commercial Tax Officer's assessment order in the present case.

Conclusion: The assessment order of the Commercial Tax Officer was not revisable under Section 15, and the impugned revisional order could not stand.

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