Revision limitation under Karnataka Sales Tax law runs from initiation, not completion, when proceedings begin within four years.

Revisional proceedings under section 21 of the Karnataka Sales Tax Act were held to be valid if initiated within four years, even if concluded later. The Court followed binding local precedent that treats initiation of revision as the ative statutory act, and declined to prefer a contrary view from another High Court on completion within the limitation period. The petitioner's objection to the factual basis for invoking revision was treated as a matter more appropriately raised in statutory appeal, and the challenge therefore failed.

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Issues: Whether revisional proceedings under section 21 of the Karnataka Sales Tax Act, 1957 had to be both initiated and completed within four years, or whether initiation within four years was sufficient.

Analysis: A prior Division Bench decision interpreting section 21 had already held that the decisive act is the initiation of revision within four years and that completion may take place thereafter. The Court noted that a contrary view from another High Court on the requirement of completion within the statutory period could not displace the binding local precedent. The petitioner's further challenge on the factual basis for exercise of revision was treated as a matter more appropriately examined in statutory appeal.

Conclusion: The revisional proceedings were valid if initiated within four years, even though concluded later, and the petitioner's challenge failed.

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