Revisional power confined to the original record; a later judgment cannot justify reopening a concluded assessment.

Revisional power under Section 10B is confined to testing the legality and propriety of the assessment order on the material available when that order was passed. A judgment delivered after the assessment is not part of the record existing on that date and cannot, by itself, furnish a valid foundation for revision. On that basis, initiation of proceedings under Section 10B solely because of a subsequent decision was impermissible, and the revisional and appellate orders could not stand.

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Issues: Whether proceedings under Section 10B could be initiated on the basis of a subsequent judgment not on record at the time of the assessment order.

Analysis: The revisional power under Section 10B is limited to examining the legality and propriety of the assessment order on the basis of the material that existed on the record when that order was passed. A later judgment does not constitute material available on that date. Since the revisional proceedings were initiated only on the basis of a subsequent decision pronounced after the original assessment, the foundation for invoking Section 10B was impermissible.

Conclusion: The invocation of Section 10B on the basis of a subsequent judgment was not sustainable and the revisionists succeeded on this issue.

Final Conclusion: The impugned revisional and appellate orders could not stand, and the revisions were allowed with consequential relief.

Ratio Decidendi: Revisional power is confined to the record existing on the date of the original order, and a subsequent judgment cannot by itself justify reopening or revising that concluded assessment.

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