Statutory limitation runs from communication to the Commissioner, not receipt by a subordinate officer, under sales tax revision rules.

The Rajasthan Sales Tax Act, 1954 fixed the 180-day period for filing a revision from communication of the Tribunal's order in writing to the Commissioner, because the Commissioner alone had authority to direct filing of the revision. A procedural form under the Rules could govern filing mechanics, but it could not alter or shorten the statutory limitation period by referring to receipt of the order by a Commercial Taxes Officer. The statutory clock therefore ran from communication to the Commissioner, and the revision was treated as within limitation.

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Issues: Whether the period of 180 days for filing a revision under the Rajasthan Sales Tax Act, 1954 ran from the date on which the Tribunal's order was communicated to the Commissioner or from the date on which it was received by the Commercial Taxes Officer filing the revision.

Analysis: The statutory scheme required the Tribunal to send its order to the Commissioner, and the power to direct a Commercial Taxes Officer to file a revision vested in the Commissioner alone. The limitation provision expressly tied the 180-day period to the date on which the order was communicated in writing to the Commissioner. A prescribed form under the Rules could regulate procedure for filing the revision, but it could not control or curtail the substantive limitation fixed by the Act. Acceptance of the contrary view would permit internal departmental delay to alter the statutory period, which the legislative language did not permit.

Conclusion: The limitation period was held to run from communication of the order to the Commissioner, not from receipt by the Commercial Taxes Officer, and the revision was within limitation. The preliminary objection was dismissed.

Ratio Decidendi: Where a statute expressly fixes limitation from communication of the order to a specified statutory authority, a procedural form cannot override or shorten that period by referring to receipt by a subordinate officer.

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