JUDGMENT M.C. Desai, C.J. - The respondent in this special appeal, which is a company, admittedly derived agricultural income during the assessment year in question viz. 1361 Fasli and was liable to be assessed to tax on it under Sec. 3 of the U.P. Agricultural Income-tax Act. Under sub-Sec. (2) of Sec. 15 of the Act it is the duty of principal officer of every company to furnish to the Collector every year a return of its agricultural income during the previous year. Sub-Sec. (3) provides that the assessing authority may serve a notice requiring a person, whose agricultural income is liable to be taxed, to furnish to him within a certain time a return in the prescribed form setting forth along with such other particulars as may be provided for in the notice) his total agricultural income during the previous year. Sub-Sec. (3-B), is to the effect that the assessing authority should send along with a notice under sub-Sec. (3) a statement showing the provisional estimate of the agricultural income prepared in accordance with the provisions of clause (a) of sub-sec. 6(2). sub-Sec. (4) reads as follows:- "If any person having furnished a return under sub-Sec. (1), (2) or (3) discovers any omission or wrong statement therein he may furnish a return or a revised return, as the case may be, at any time before the assessment is made and any return so made shall be deemed to be made in due time and under this section." Sec. 6 lays down the method of computation of the agricultural income; it is to be computed at the option of the assessee in accordance with Cl. (a) or Cl. (b) of sub-Sec. (2). The option of having the income computed in accordance with Cl. (a) will be referred to as option (a) and the other option, as option (b). The assessment procedure is laid down in Sec. 16. If a return filed under Sec. 15 is found by the assessing authority to be correct and complete it is to assess the income accordingly and determine the tax payable by the assessee. If it has reason to believe that it is incorrect or incomplete it is required by sub-Sec. (2) to serve a notice upon the assessee calling upon him to produce evidence in support of it. If it has reason to believe that it is incorrect or incomplete it is required by sub-Sec. (2) to serve a notice upon the assessee calling upon him to produce evidence in support of it. After seeing the evidence produced by the assessee, it should make an order in writing assessing the income and determine the tax payable thereon. If the principal officer of a company fails to make a return or fails to comply with a notice issued by the assessing authority or to produce evidence, the assessing authority is authorised to assess it to the best of its judgment with regard to the statement if any sent under Sec. 15 (3-B) notwithstanding any option exercised under Sec. 6(1). Rule 5 made by the State Government in exercise of the powers conferred under the Act lays down:- "An assessee shall, along with his return of income, file a declaration in Form A. I. T. 2 indicating his option under sub-Sec. (1) of Sec. 6." Under Rule 6, the declaration is to be preserved by the assessing authority in a separate guard file. The form A. I. T. 2 is as follows:- "In pursuance of Sec. 6 (1), I..............do hereby declare that I have elected the method of computation of agricultural income provided by Sec. 6(2) (a)/6 (2) (b) and have computed my income accordingly." 2. The respondent assesses filed its return on 27-11-54 under Sec. 15(2) and attached to it a declaration -selecting option (b). The assessing authority served upon it the notice referred to in Sec. 15(3) on 7-4-1955 and attached to the notice a provisional estimate of its income computed in accordance with option (a). In the meantime on 4-4-1955 the assessee discovering some mistake in its return filed a revised return, still computing the income in accordance with option (b). In this return it claimed further deductions on account of expenses. The revised return was not believed by the assessing authority to be correct or complete with the result that it served upon it a notice, as required by Sec. 16(2). On 14-4-1955, in reply, the assessee filed some evidence. On 29-9-1955 the assessing authority served upon the assessee another notice stating that its income had escaped assessment to the extent of Rs. 38,000/- and odd. On 14-4-1955, in reply, the assessee filed some evidence. On 29-9-1955 the assessing authority served upon the assessee another notice stating that its income had escaped assessment to the extent of Rs. 38,000/- and odd. The notice purported to have been issued under Sec. 16(2), but it could not have been given under any provision except perhaps Sec. 15(3) (b). The assessee then inspected the record in order to file an objection against the notice issued to it. On the date fixed for the hearing of the objection, 8-11-1958, the assessee filed a third return along with another declaration selecting option of and prayed that it should be allowed to change the option exercised on the previous two occasions. The assessing authority on 17-11-1959, refused permission to change the option. The assessee filed an application to the Board of Agricultural Income to revise the order of the assessing authority and the Revision Board rejected the application. The assessee then applied for certiorari, mandamus etc. for the quashing of the orders of the assessing authority and the Board and the application has been allowed by Brijlal Gupta, J. This Special Appeal is against his order. The connected application is under Sec. 24(4) for calling upon the Board to state the case and refer it to this Court. The assessee had applied to the Board under Sec. 24 (2) to state the case and refer the question of law arising out of its order to this Court but it had refused to do so on the ground that no question of law arose out of its order. 3. The first question that we have to answer in this appeal is whether an option once exercised by an assessee can be revised by him if he files a return or revised return under Sec. 15(4). Sec. 15(4) deals with a person who has furnished a return; it gives him a right to furnish a return or a revised return, as the case may be, on his discovering any omission or wrong statement in the furnished return. It is not understood what is meant by "as the case may be" and the only meaning that can be given to the phrase is that if there is an omission in the furnished return he furnishes another return and if there is a wrong statement in it he furnishes a revised return. It is not understood what is meant by "as the case may be" and the only meaning that can be given to the phrase is that if there is an omission in the furnished return he furnishes another return and if there is a wrong statement in it he furnishes a revised return. It is beyond comprehension why there is this distinction between what he does to remove an omission and what he does to remove a wrong statement. Why is it called a return in one case and a revised return in the other case? Here the assessee furnished a return under Sec. 15(2) which will be called the original return, and then furnished two returns in exercise of the power conferred by Sec. 15(4). The power was exercised not on the ground of an omission in the original return but on ground of wrong statements therein. Therefore, the two returns filed by him subsequently are revised returns and certainly not mere returns. Brijlal Gupta, J., has said in his judgment that there is no distinction between a return and a revised return, but we find it difficult to agree because Sec. 15(4) makes a clear distinction between a "return" and a "revised return" by using both in juxtaposition and emphasised it by using the words "as the case may be." The provision in Sec. 15(4) that "any return so made shall be deemed to be made in due time" does not remove the distinction between a "return" and a "revised return"; the word "return" there is used in the wider or generic sense including a revised return. The word there necessarily means both a return (in the narrow sense) and a revised return. It does not follow that there is no distinction between a "return" and a "revised return." 4. The option that is conferred by Sec. 6 has to be exercised in accordance with the provisions of the Act and the Rules and the only provision is that contained in Rule 5. Consequently, the option has to be exercised by filing a declaration along with the return. A declaration can be filed under Rule 5 with a return, not with a revised return. The word "return" is evidently used in the narrow sense. The Legislature has distinguished between a return and a revised return but the State Government has used the word "return" only in rule 5. A declaration can be filed under Rule 5 with a return, not with a revised return. The word "return" is evidently used in the narrow sense. The Legislature has distinguished between a return and a revised return but the State Government has used the word "return" only in rule 5. There is logic behind an assessees not being required to, file another declaration with his revised return; a revised return becomes necessary only on account of a wrong statement in the original return, and not on account of any mistake or defect in the declaration. If there is a wrong statement in an original return it would only necessitate the furnishing of a revised return but there would be no necessity of filing a fresh declaration along with it. As there is no necessity of filing a fresh declaration along with a revised return there is no provision requiring the assessee to file a declaration-along with every revised return. The wrong statement referred to in Sec. 15(4) has no connection with the option exercised. A statement does not become wrong merely because the assesses has selected the wrong option. He does not get the right of filing a revised return under Sec. 15(4) merely because he wishes to change the option. The provision that the declaration must be kept in a guard file, shows that the option once exercised is to remain in force permanently. Previously an assessee could not change an option in a subsequent year, but now the law has been amended and he can change it but it does not follow that he can change it during the assessment year. It was contended that there is no provision which bars an assessees changing the option but what one has to search for is a provision conferring upon him the right to change the option rather a provision prohibiting a change in the option. The reason is that the existence of an option does not include within itself the right to change the option. An assessee has a right to select one option or the other but it is lost when he exercises it by selecting an option or the other. There is no question of exercising it again. The right of changing the option once exercised is quite different from the right of option. An assessee has a right to select one option or the other but it is lost when he exercises it by selecting an option or the other. There is no question of exercising it again. The right of changing the option once exercised is quite different from the right of option. Once he has exercised the option the right comes to an end and if he wants to change the option the right to do so must be conferred upon him. No right has been conferred upon an assessee to change the option contained in a declaration. The manner of exercising the option is laid down exclusively in the Rules and there is nothing in Rules 5 and 6, which are the only rules dealing with the exercise of option, to suggest that an option once exercised can be altered. An assessee, who receives a notice under Sec. 16(2) may exercise the power conferred by Sec. 15(4) and furnish a revised return but the right to furnish a revised return does not include the right to revise the option. Therefore, the respondent got no right to revise the option merely because of receipt of a notice under Section 16(2) from the Assessing Authority. The only right that it acquired was to produce evidence in support of the return filed by it or to furnish a revised return. Sec. 15(4), was enacted for the purpose of giving locus paenitentiae to an assessee, who has furnished a return containing a wrong statement. Under Sec. 17 of the Act, an assessee is liable to be punished for concealing the particulars of his agricultural income or deliberately furnishing inaccurate particulars of his income. An assessee is allowed locus paenitentiae to escape the penalty and consequently has given a right to furnish a revised return under Sec. 15(4) but no such consideration arises in respect of a declaration containing an option. There is no question of locus paenitentiae in respect of selection of an option; it is expected to be done after weighing the pros and cons of the two options. 5. We are, therefore, of the opinion that the respondent had no right to change the option. 6. This Court acting under Article 226 of the Constitution exercises not appellate jurisdiction but supervisory jurisdiction and is concerned only with seeing that the inferior Tribunal has kept itself within its jurisdiction. 5. We are, therefore, of the opinion that the respondent had no right to change the option. 6. This Court acting under Article 226 of the Constitution exercises not appellate jurisdiction but supervisory jurisdiction and is concerned only with seeing that the inferior Tribunal has kept itself within its jurisdiction. The Revision Board exercised its revisional jurisdiction and refused to interfere with the order of the assessing authority on finding nothing wrong with it. We do not exercise appellate jurisdiction over the order passed by the Revision Board and if it kept itself within its jurisdiction we are powerless to interfere with the order passed by it even though it may be wrong or we may not agree with it. Only if it was manifestly wrong we could say that it had failed to exercise jurisdiction vested in it or exercised jurisdiction not vested in it by taking the manifestly erroneous view of the law. But it is not possible for this Court to say that the view that it took that the assessee had no right to change the option is manifestly erroneous. The order passed by it, therefore, was not liable to be quashed by certiorari. 7. We, therefore, allow this appeal and restore the order passed by the Revision Board. The State will get its costs of the appeal from the respondent.