Limitation for sales tax revision runs from the date of issue of notice, not service on the assessee.

For limitation under the proviso to section 39(2) of the Madhya Pradesh General Sales Tax Act, 1958, revision proceedings commence on the date the revisional notice is issued, not on the date it is served on the assessee. Applying that binding view, the court treated the notice dated 20 April 1971 as issued within the three-year limitation period, so the revision was not time-barred.

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Issues: Whether, for the purpose of limitation under the proviso to section 39(2) of the Madhya Pradesh General Sales Tax Act, 1958, revision proceedings are deemed to commence on the date the notice is signed, the date it is issued by the office, or the date it is served on the assessee.

Analysis: The question was answered by applying the earlier binding view that, for computing the three-year limitation prescribed for revision under section 39(2), the relevant date is the date on which the notice is issued and not the date of service. On that basis, the revision notice dated 20 April 1971 was treated as having been issued within time.

Conclusion: The limitation for proceedings under section 39(2) begins from the date of issue of the notice, and the revision was not barred by time.

Ratio Decidendi: For limitation under section 39(2) of the Madhya Pradesh General Sales Tax Act, 1958, the decisive date is the date of issue of the revisional notice, not the date of its service.

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