Revisional jurisdiction cannot serve as a substitute for filing...

Revisional jurisdiction cannot serve as a substitute for filing a revised return after the statutory deadline. A fresh claim may be considered only where it raises a new question of law on foundational facts already before the Assessing Officer; claims requiring facts not placed before that authority fall outside revisional jurisdiction. The Tribunal's plenary appellate power to entertain a legal point does not expand the revisional authority's powers. This framework confines revision to the existing factual record and prevents its use to introduce a new fact-based tax claim.