Compounding of offence is complete on acceptance and payment, barring later revision or challenge to the order.

Compounding under section 47 of the Kerala General Sales Tax Act is complete only when the assessee accepts the compounding order and pays the compounding fee, because the process operates as a bilateral arrangement by which the State agrees not to prosecute in return for payment. Once that payment is made, the assessee cannot later challenge the completed compounding or reopen alleged mistakes in the order. Any objection had to be raised before payment, and no revision lies under sections 36 or 38 in relation to a completed composition.

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Issues: Whether a revision lay against an order compounding an offence under the Kerala General Sales Tax Act, 1963 after the assessee had accepted the compounding order and paid the compounding fee.

Analysis: Composition of an offence under section 47 is complete only when the assessee accepts the order and pays the fee, because compounding is treated as a bilateral arrangement by which the State agrees not to prosecute on payment of consideration. Once payment is made, the assessee cannot later challenge the completed compounding or reopen alleged mistakes in the compounding order. Such grievances, if any, had to be raised before payment, and after completion of composition there is no scope for revision under section 36 or section 38 in relation to the completed compounding.

Conclusion: The revision was not maintainable after payment of the compounding fee, and the petitioner was not entitled to interference with the compounding order.

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