Self-contained limitation scheme bars importing a general proviso to extend rectification time under a validating amendment.

A validating amendment with an express limitation scheme for review and rectification prevails over the general proviso in the principal sales tax provision. The proviso to section 22 of the U.P. Sales Tax Act could not be imported into section 39 of the U.P. Sales Tax (Amendment) Act, 1995, because section 39 separately fixed the time for review applications and rectification orders. Reading the proviso into section 39 would undermine the distinct statutory timelines and make the specific limitation in the amendment redundant. Rectification orders made after 14 March 1996 were therefore time-barred, and the Tribunal's order was restored.

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Issues: Whether the proviso to section 22 of the U.P. Sales Tax Act, 1948 could be invoked to extend the time for passing rectification orders under section 39(2) and section 39(3) of the U.P. Sales Tax (Amendment) Act, 1995, and whether the Tribunal's rectification orders were within limitation.

Analysis: Section 39 of the Amendment Act was enacted as a validating and enabling provision to bring earlier orders into conformity with the amended principal Act. Sub-section (2) permitted an application for review to be made by September 30, 1995, while sub-section (3) separately provided that rectification could be made within one year from commencement of the section or within the period specified in section 22 of the principal Act, whichever expired later. The proviso to section 22 only allowed disposal beyond three years where an application had been made within that period and could not be imported to enlarge the time scheme expressly fixed by section 39. Reading the proviso into section 39 would make the specific limitation in sub-section (3) redundant and would blur the distinct statutory powers of review and rectification.

Conclusion: The proviso to section 22 had no application to proceedings under section 39, and the rectification orders passed after March 14, 1996 were time-barred.

Final Conclusion: The appeals succeeded, the High Court's view was set aside, and the Tribunal's order was restored.

Ratio Decidendi: Where a validating amendment contains an express and self-contained limitation scheme for review or rectification, that scheme prevails and the general proviso governing rectification under the principal Act cannot be used to extend the statutory time limit.

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