Revisional limitation turns on the substance of the order revised, not the mistaken date recited in the revisional order.

In revisional limitation under the Tamil Nadu General Sales Tax Act, the controlling question was the substance of the order actually revised, not the mistaken date recited in the revisional order. The record showed an original assessment followed by rectification, and the revisional exercise in substance targeted the rectified order. On that basis, the revision was not necessarily time-barred. The Tribunal had proceeded on an incorrect view of which order was under challenge, so its setting aside of the revisional order was reversed and the matter remitted to the Tribunal for fresh disposal on the correct facts after hearing the assessee.

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Issues: Whether the revisional order was barred by limitation under section 32 of the Tamil Nadu General Sales Tax Act, 1959, depending on whether the revisional authority had in substance revised the original assessment order or the later rectification order.

Analysis: The assessment record showed an original order of assessment followed by a subsequent rectification. The revisional authority described the order under revision as the original assessment order, but the substance of the revisional exercise showed that the later rectified order alone was really under challenge. Since the date mentioned in the revisional order was not decisive, the true nature of the order had to be ascertained from the contents of the revisional order and the assessment record. On that basis, the revisional order was not necessarily time-barred, and the Tribunal had proceeded on an incorrect understanding of the order actually revised.

Conclusion: The objection of limitation was not accepted; the Tribunal's setting aside of the revisional order was reversed.

Final Conclusion: The matter was sent back to the Tribunal for fresh disposal on the correct facts and in accordance with law, after giving the assessee an opportunity of hearing.

Ratio Decidendi: For determining limitation in revisional proceedings, the substance of the order actually revised, and not merely the erroneous date recited in the revisional order, is controlling.

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