Delay in communicating a valid revisional order can defeat enforceability when it causes prejudice and unfairness.

A revisional order under section 20(3) of the Andhra Pradesh General Sales Tax Act, 1957, was held to be within limitation because it was made within four years from service of the appellate order. However, the Court treated the prolonged delay in communicating that order to the assessee as fatal on the facts, holding that administrative action affecting rights must be conveyed within a reasonable time. The inordinate delay caused prejudice and was inconsistent with fairness and the rule of law, so the order, though validly made, was not binding on the assessee.

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Issues: Whether a revisional order passed within the prescribed period under section 20(3) of the Andhra Pradesh General Sales Tax Act, 1957, but communicated to the assessee after an inordinate delay, could be treated as binding on the assessee.

Analysis: The revisional power under section 20(3) was exercised within four years from the date on which the appellate order was served, so the order was not barred by limitation and was not beyond jurisdiction. However, the Court held that even where the power is validly exercised, administrative action affecting rights must be communicated within a reasonable time. The long delay in serving the revisional order created prejudice and was inconsistent with the requirements of fairness and the rule of law. The delay was found to be grossly unreasonable on the facts.

Conclusion: The revisional order, though within limitation, was not binding on the assessee because of the inordinate and unreasonable delay in communication, and the challenge succeeded.

Ratio Decidendi: Where a statutory revisional order is lawfully made within time, it may still lose enforceability against the affected party if, on the facts, it is communicated only after an inordinate and unreasonable delay that causes prejudice.

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