Limitation for suo motu revision runs from initiation by calling for records, not from completion of proceedings.

Section 22-A(2) of the Karnataka Sales Tax Act, 1957 was read as requiring only that suo motu revision be initiated within four years from the date of the order sought to be revised. The court held that the power is exercised when the records are called for, so completion of the revisional proceedings after four years does not by itself bar the action. As the Commissioner's office record showed that the records were called specifically for revision within the limitation period, the challenge based on delay and alleged improper purpose failed. The revisional order restoring the assessment was upheld.

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Issues: Whether the Commissioner's revisional power under section 22-A(2) of the Karnataka Sales Tax Act, 1957 had to be fully concluded within four years from the date of the order sought to be revised, or whether it was enough if the proceedings were initiated within that period by calling for the records.

Analysis: The revisional power under section 22-A is a judicial or quasi-judicial power that begins with the Commissioner calling for and examining the records. The expression that the power shall be exercisable within four years was construed to govern initiation of the revisional process and not its completion. The court held that once the records were called for within four years, limitation was satisfied, even if the final revisional order was passed later. The earlier binding ruling on the same statutory language was followed, and the parallel views of other High Courts were approved.

Conclusion: The limitation objection failed, and the revisional order was validly made within the meaning of section 22-A(2) of the Karnataka Sales Tax Act, 1957.

Ratio Decidendi: For a statutory revisional power framed as being exercisable within a specified period, limitation is satisfied by the initiation of revision proceedings within that period, and not by completion of the proceedings or passing of the final order within that period.

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