Suo Moto Revision Requires More Than Erroneous Order: Must Show Incorrect Tax Imposition or Statutory Misinterpretation.

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....Suo moto revision - Eligibility for deduction of the entire sub-contractors' payments made - Both the circumstances must co-exist before the revisional authority can initiate suo moto revisional proceedings. That, it is not sufficient to vest power in the respondent/authority to exercise suo moto revision merely because an order is erroneous - there must be some prima facie material on record to show that tax which was lawfully exigible has not been imposed or that by the application of the relevant statute on an incorrect or incomplete interpretation a lesser tax than what was just has been imposed. - HC....