Entertainment tax revision power survives the option period when the triggering event occurred within time, Supreme Court held.

The Supreme Court of India construed section 5(6) of the Andhra Pradesh Entertainments Tax Act, 1939, and rule 27(13) of the Andhra Pradesh Entertainments Tax Rules, 1939, to mean that the period of option limits when the triggering events must occur, not when the taxing authority may revise the fixed entertainment tax. The words "at any time" preserved the power to act after that period, so a revision based on events occurring within the option period was valid even if the demand was issued later. Rule 27(13), using the same broad language, was held consistent with the section.

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Issues: Whether the power to vary the entertainment tax under section 5(6) of the Andhra Pradesh Entertainments Tax Act, 1939 and rule 27(13) of the Andhra Pradesh Entertainments Tax Rules, 1939 could be exercised only during the period of option, and whether demands raised after expiry of that period were invalid.

Analysis: The expression "during the period of option permitted under this section at any time" was held to qualify the occurrence of the listed events, not the authority's power to act. Read in that manner, section 5(6) permits revision whenever the prescribed events occur during the option period, while "at any time" preserves the authority's power to revise thereafter. Rule 27(13), which uses only "at any time", was therefore not inconsistent with the section and did not require any restrictive reading.

Conclusion: The demands were not invalid merely because they were raised after the period of option had expired; the earlier High Court view was wrong and the Revenue's challenge succeeded.

Final Conclusion: The statutory scheme allowed revision of the fixed tax amount where the relevant triggering event occurred during the permitted period, and the timing of the revisional order itself did not by itself vitiate the demand.

Ratio Decidendi: Where statutory language links the occurrence of a triggering event to a defined period and separately preserves the authority's power to act "at any time", the time limitation governs the event, not the exercise of power, unless the text clearly says otherwise.

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