Revision limitation depends on the date of the revisional order, not service, unless abnormal unexplained delay suggests otherwise.

Limitation for revision under section 20(3) of the Andhra Pradesh General Sales Tax Act, 1957 is governed by the date the revisional order is passed, not the later date of service, unless abnormal unexplained delay in service justifies a presumption that the order was not made on its recorded date. On the facts, the revisional order was passed within the four-year period and no material supported such a presumption, so the challenge based on limitation failed.

---

---

Issues: Whether the revisional order under section 20(3) of the Andhra Pradesh General Sales Tax Act, 1957 was barred by limitation because it was served after the expiry of four years from the appellate order.

Analysis: The limitation prescribed in section 20(3) governs the exercise of revisional jurisdiction, which is complete when the revisional proceedings are initiated and the final order is passed. The relevant date is the date of the revisional order, not the later date of its service, unless the service is shown to have been delayed abnormally without explanation so as to raise a presumption that the order was not passed on its recorded date. On the facts, the order was passed within the four-year period and there was no material to draw such a presumption from the date of service.

Conclusion: The revisional order was not barred by limitation and the challenge to its validity failed.

Ratio Decidendi: For revision under section 20(3) of the Andhra Pradesh General Sales Tax Act, 1957, limitation is satisfied by initiation of revisional proceedings and passing of the revisional order within time; delayed service of the order does not by itself make the revision time-barred unless unexplained abnormal delay justifies a contrary presumption.

---