Limitation amendments apply prospectively to filings after commencement, and a revision filed out of time was barred.

An amendment changing the limitation period for revision applications under the U.P. Sales Tax Act was held to apply to revisions filed after its commencement, even where the underlying order pre-dated the amendment. The Court treated limitation as procedural and held that procedural law ordinarily governs pending and future proceedings unless a contrary intention appears. It further held that there is no vested right in a particular limitation period and that the right to seek revision is not a substantive right comparable to an appeal. Because the revision was filed after the amended one-year period had expired, it was barred by limitation.

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Issues: Whether the amended limitation provision governing revision applications under the U.P. Sales Tax Act applied to a revision filed after the amendment came into force, so as to render it time-barred.

Analysis: The amendment prescribed a period of one year from the date of service of the order complained of and applied in general terms to all orders and all services, without distinguishing between orders made or served before or after its commencement. The Court held that a law dealing with limitation is procedural in nature, and procedural laws ordinarily apply to pending and future proceedings unless a contrary intention appears. It further held that there is no vested right in a particular period of limitation, and that the right to seek revision is not a substantive right comparable to a right of appeal. Since the assessee's revision application was filed after the amended limitation period had expired, the amendment governed the filing and the application was barred.

Conclusion: The revision application was barred by limitation, and the answer to the referred question was in the affirmative, in favour of Revenue.

Ratio Decidendi: An amendment altering the period of limitation is procedural and applies to proceedings filed after its commencement, including proceedings based on antecedent facts, unless it extinguishes an already barred cause of action or a contrary legislative intention appears.

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