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Issues: Whether the Board of Revenue could exercise suo motu revisional power under section 34 of the Madras General Sales Tax Act, 1959 after four years from the date of the order sought to be revised.
Analysis: Section 34(2)(c) bars the Board from passing any order under section 34(1) if more than four years have expired after the passing of the order. The phrase is directed to the date of the subordinate authority's order itself and makes such order immune from suo motu interference after the expiry of the prescribed period. The distinction between section 34, which governs suo motu revision, and section 35, which governs revision at the instance of an assessee, shows that the Legislature imposed a strict time bar only on the Board's own-motion jurisdiction. The earlier agricultural income-tax decision did not assist the Revenue because the wording and scheme of the two enactments were materially different.
Conclusion: The Board's suo motu revisional order was time-barred and invalid, and the assessee succeeded on this issue.