Retrospective procedural amendment cannot reopen finally concluded proceedings or revive time-barred review applications.

A retrospective procedural amendment inserting section 12-A(2) could not be used to reopen proceedings that had already attained finality. The review applications were found unsustainable because one had become infructuous after the enabling Ordinance lapsed, while the other was time-barred under the later enactment. The Court also noted that the amendment could not revive a review of an order passed years earlier in finally disposed proceedings, and that its application to a Central Sales Tax transaction was itself debatable. The review applications were therefore not maintainable and were rejected.

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Issues: Whether the review applications against the earlier order could be entertained on the basis of the subsequent amendment inserting section 12-A(2), and whether the amended provision could reopen proceedings already concluded.

Analysis: The applications were found unsustainable on multiple grounds. The first review application had become infructuous because the enabling Ordinance had lapsed. The second application was held to be barred by time under the later enactment. Independently, the amendment inserting section 12-A(2) was treated as procedural in nature, and the Court held that even retrospective procedural law does not revive or reopen matters that have already attained finality. The Court also observed that the amendment could not be used to review an order passed years earlier in finally disposed proceedings. A further obstacle was that the question whether section 12-A(2) could be applied to a transaction under the Central Sales Tax Act was itself debatable, and therefore the amendment could not furnish a basis for review.

Conclusion: The review applications were not maintainable and were rejected.

Ratio Decidendi: A retrospective procedural amendment cannot be invoked to reopen or review proceedings that have already been finally concluded, and a time-barred or infructuous review application cannot be revived by such amendment.

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