Revisional limitation under sales tax law: a delayed withdrawal of exemption was barred because the saving provisions did not apply.

A revisional order withdrawing tax exemptions was time-barred because the statutory four-year period for revision under the Andhra Pradesh General Sales Tax Act and the relevant Rules had expired, and the order was made nearly seven years after assessment. The saving provision for giving effect to a finding or direction did not apply because the revision was not made for that purpose. The provision suspending limitation during stay or pending proceedings also did not apply because no qualifying stay or proceeding existed. The revisional order was therefore unsustainable.

---

---

Issues: Whether the Deputy Commissioner's revisional order withdrawing the exemptions was barred by limitation under the Andhra Pradesh General Sales Tax Act, 1957, and whether the limitation could be saved under the relevant statutory provisions.

Analysis: The revisional order was made nearly seven years after the assessment order. Section 20(3) of the Andhra Pradesh General Sales Tax Act, 1957 and Rule 14-A(8), Rule 14-A(9) and Rule 14-A(11) of the Central Sales Tax (Andhra Pradesh) Rules, 1957 prescribed a four-year period for exercise of revisional power, and the order was outside that period. Section 24-A of the Andhra Pradesh General Sales Tax Act, 1957 was inapplicable because the revisional order was not made to give effect to any finding or direction under the specified provisions. Section 20(6) of the Andhra Pradesh General Sales Tax Act, 1957 also did not apply because there was no stay of proceedings by the High Court or the Supreme Court, nor any pending proceeding of the kind contemplated by that provision.

Conclusion: The revisional order was barred by limitation and could not be sustained.

Final Conclusion: The revision failed because the Tribunal was correct in holding that the reassessment revision was time-barred and unsaved by the cited provisions.

Ratio Decidendi: A revisional order must be made within the statutory limitation period, and a saving provision can operate only when its specific preconditions are satisfied.

---