Suo motu revision limitation is read pragmatically when records are already before the Commissioner and examined in time.

Suo motu revision under section 22-A of the Karnataka Sales Tax Act, 1957 was construed in a practical manner for limitation purposes. Where the appellate records were already before the Commissioner and he applied his mind to them within the statutory period, that examination could amount to initiation of revision, even without a separate formal call for records. The expression "exercisable" was read broadly to cover effective action, and the limitation provision was not given a narrow or pedantic meaning. On that approach, substantial compliance with the four-year requirement was accepted and the revision was treated as initiated in time.

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Issues: Whether the Commissioner's exercise or initiation of suo motu revision under section 22-A of the Karnataka Sales Tax Act, 1957 was within the prescribed four-year period and therefore not barred by limitation.

Analysis: The period in section 22-A(2) was construed in the context of the Commissioner having received the appellate records from the subordinate authority and having applied his mind to them. The power to call for records was treated as a means to secure and examine records, and the absence of a formal call by the Commissioner did not prevent the records already before him from being examined for revision. The expression "exercisable" was read broadly to include taking effective action, and the Commissioner's examination of the records and decision to await the Supreme Court's ruling were held to amount to initiation within time. The provision was not given a narrow or pedantic construction, and substantial compliance with the limitation requirement was accepted.

Conclusion: The revision proceedings were held to have been initiated within time and were not barred by limitation; the challenge to the notices failed.

Final Conclusion: The writ petitions failed on the limitation challenge to the Commissioner's suo motu revisional action under the Karnataka Sales Tax Act, 1957.

Ratio Decidendi: Where revision records are already before the Commissioner and he applies his mind to them within the statutory period, such examination can constitute initiation of suo motu revision for limitation purposes, and the limitation provision is to be read in a practical and substantial manner.

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