Registered post does not complete filing within limitation unless the statute deems posting to be presentation.

Where a statute requires a revision application to be made or presented within a prescribed period and allows filing by registered post without creating a deeming fiction, presentation is complete only on receipt by the revising authority, not on the date of posting. The M.P. General Sales Tax Act and Rule 57 were read as requiring actual presentation within twelve months, with registered post treated only as a mode of transmission. The contrary view that dispatch within time was sufficient was rejected as inconsistent with the statutory language. On that construction, a revision received after expiry of limitation was barred by time.

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Issues: Whether a revision application under section 39 of the M.P. General Sales Tax Act, 1958, sent by registered post within the limitation period is deemed to have been presented within time when it is received by the revising authority after expiry of limitation.

Analysis: The statutory scheme required a revision to be made or presented within twelve months, and rule 57 permitted filing either by personal presentation, through an authorised agent, or by registered post. The majority held that the expressions "made within" and "presented within" were intended to mean actual presentation to the revising authority, and that dispatch by post did not complete presentation until receipt by the authority. The rule permitting registered post was treated as a mode of transmission, not as a deeming provision making the date of posting decisive. The contrary view, based on convenience, was rejected as inconsistent with the language of the Act and Rules and with the limitations of statutory interpretation. The dissenting opinion held that posting within time was sufficient.

Conclusion: The revision application was barred by limitation because it was presented only when received by the revising authority, not when posted, and the petition failed.

Ratio Decidendi: Where a statute requires an application to be made or presented within a prescribed period and permits sending it by registered post without creating a deeming fiction, presentation is complete only on receipt by the authority and not on the date of posting.

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