Revisional power "at any time" cannot be cut down by implied limitation or a different escaped-assessment rule.

Section 15(2) of the Hyderabad General Sales Tax Act empowered the Commissioner to revise suo motu "at any time", and that expression was held to permit exercise of revisional power without any implied three-year limit. Rule 32 of the Hyderabad General Sales Tax Rules, 1950, which governed escaped assessment proceedings, could not be used to curtail or qualify a distinct revisional jurisdiction. The later repeal under the Andhra Pradesh General Sales Tax Act, 1957, did not control a revision arising from an assessment made under the Hyderabad Act. The challenge to the revisional order therefore failed on limitation grounds.

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Issues: Whether the Commissioner's revisional power under section 15 of the Hyderabad General Sales Tax Act was subject to an implied three-year limitation, or to the limitation contained in rule 32 of the Hyderabad General Sales Tax Rules, 1950, or to the limitation in section 20 of the Andhra Pradesh General Sales Tax Act, 1957.

Analysis: Section 15(2) expressly empowered the Commissioner to act suo motu "at any time", and that phrase was held to be of definite import denoting an indefinite period. No warrant was found for reading into the provision a limitation period merely because another rule, dealing with escaped assessment, prescribed time limits for a different kind of proceeding. Rule 32 was not a revisional provision and could not control or qualify the revisional power under section 15. The later repeal by the Andhra Pradesh General Sales Tax Act, 1957 also did not govern the matter, since the assessment itself had been made under the Hyderabad Act and the revisional jurisdiction had to be exercised under that Act.

Conclusion: No implied period of limitation could be read into section 15, and the Commissioner's revisional order was valid.

Final Conclusion: The challenge to the Commissioner's revision failed, and the assessee was not entitled to relief on the ground of limitation.

Ratio Decidendi: Where a taxing statute confers revisional power to be exercised "at any time", a court cannot import a period of limitation by implication, and a different rule framed for escaped assessments cannot curtail that express power.

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