Revisional limitation under sales tax law requires final order within the statutory period, not just a notice

Revisional power under section 20(3) of the A.P. General Sales Tax Act is exercisable only within the prescribed four-year period, and the entire revisional process must be completed by passing the final order within that period unless time is expressly excluded under sub-sections (5) and (6). Mere issue of a show-cause notice within four years does not satisfy the statutory limit, because the power continues until the revision is concluded. On this construction, the limitation bar operated against the Revenue, and the Tribunal's dismissal of the revenue challenge was sustained.

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Issues: Whether, under section 20(3) of the A.P. General Sales Tax Act, 1957, revisional power in relation to an assessment order is validly exercised merely by issuing a show-cause notice within four years, or whether the revisional authority must complete the revision by passing the order within the four-year period, subject to exclusions provided by sub-sections (5) and (6).

Analysis: The statutory scheme treats the four-year period as an outer limit for the exercise of revisional power in relation to an assessment order. The commencement of revision by notice does not exhaust the requirement of the provision, because the power continues until the final revisional order is made and the process is completed. Sub-sections (5) and (6) indicate that the Legislature contemplated exclusion of time only where a revisional order has already been passed and set aside, or where proceedings are deferred because of stay or pendency before a higher court. Reading section 20(3) together with those provisions and with section 20(2-A) supports the conclusion that the entire revisional exercise must be brought to completion within the prescribed period, subject to legally excluded intervals.

Conclusion: Mere initiation of revision within four years is not sufficient. The revisional authority must complete the exercise within the statutory period, and the limitation bar applied against the Revenue.

Final Conclusion: The revisions failed on limitation, and the Tribunal's dismissal of the revenue's challenge was sustained.

Ratio Decidendi: Where a statute provides that revisional powers in relation to an assessment order shall be exercisable only within a prescribed period, the whole revisional process, including the making of the final order, must be completed within that period, subject only to express exclusions of time.

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