Revisional limitation under entry tax law begins when records are called for, not when show-cause notice is issued.

Section 15 of the Karnataka Tax on Entry of Goods Act was construed as a suo motu revisional power that begins when the revisional authority calls for and examines the records, not only when a show-cause notice is issued. The Court held that there was no separate statutory requirement for notice to initiate revision, and that this step constituted commencement of revisional jurisdiction for limitation purposes under section 15(4). It further held that section 15B distinguishes initiation from completion of proceedings, with section 15(4) governing commencement and section 15B the outer time-limit for passing the revisional order. The revision was therefore within limitation and validly initiated.

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Issues: Whether the revisional authority under section 15 of the Karnataka Tax on Entry of Goods Act, 1979 exercised jurisdiction within the prescribed period when it called for the records for examination before issuing the show-cause notice.

Analysis: The revisional power under section 15(1) was a suo motu supervisory power exercisable on satisfaction that the subordinate order was erroneous and prejudicial to revenue. The Court held that there was no separate statutory requirement for issuance of a show-cause notice to initiate revision under section 15. The act of calling for and examining the records was treated as the exercise and commencement of revisional jurisdiction for the purpose of section 15(4). The Court further held that section 15B drew a distinction between initiation of proceedings and completion of proceedings, and that section 15(4) governed the limitation for commencement while section 15B governed the outer time-limit for passing the revisional order. The provision was treated as retrospective in its application to pending matters.

Conclusion: The revisional proceedings were within limitation and were validly initiated when the records were called for. The challenge to the High Court's view on limitation failed.

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