Revisional limitation under sales tax law depends on recorded nondisclosure; without fresh material, alternate revision provision cannot apply.

Revisional power exercised on the ground that an assessment was illegal or improper is governed by the shorter four-year limitation under section 14(4-A) of the Andhra Pradesh General Sales Tax Act, 1957 unless there is a finding that the dealer failed to disclose turnover or particulars correctly; here no such finding was recorded, so the revisional order was time-barred and unsustainable under section 14(4). The revision also could not be upheld under section 20(2) because no fresh material was shown before the revisional authority and the true nature of the exercise remained unchanged. The Tribunal's order was affirmed and the revision petition failed.

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Issues: (i) Whether the revisional order under section 14(4) of the Andhra Pradesh General Sales Tax Act, 1957 was barred by limitation under section 14(4-A); (ii) Whether the revision could be sustained as one under section 20(2) of the Act in the absence of fresh material.

Issue (i): Whether the revisional order under section 14(4) of the Andhra Pradesh General Sales Tax Act, 1957 was barred by limitation under section 14(4-A).

Analysis: The revised assessment was made on the ground that the original assessment was illegal and improper, and no finding was recorded that the dealer had failed to disclose turnover or particulars correctly. In the absence of such a finding, the case did not fall within the six-year period under clause (a) of section 14(4-A), and the revisional power could be exercised only within four years from the expiry of the assessment year. On the facts, that period had expired before the revisional order was passed.

Conclusion: The revisional order was barred by limitation and was not sustainable under section 14(4).

Issue (ii): Whether the revision could be sustained as one under section 20(2) of the Act in the absence of fresh material.

Analysis: The Tribunal found that merely referring to section 14 did not alter the true nature of the revisional exercise, and there was no fresh material before the revisional authority to attract section 20(2). No basis was shown to disturb that finding.

Conclusion: The revision could not be upheld under section 20(2).

Final Conclusion: The Tribunal's order was affirmed and the revision petition failed.

Ratio Decidendi: Where revisional power is exercised on the ground of illegality and no finding is recorded that the dealer failed to disclose turnover correctly, the longer limitation period does not apply and the shorter limitation period governs; a revisional order also cannot be sustained under a different provision without fresh material bringing the case within that provision.

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