Reasonable-time limit for suo motu revision bars reopening a final assessment after an inordinate delay.

Even where section 21(1) of the Punjab General Sales Tax Act, 1948 prescribed no express limitation for suo motu revision, the revisional authority was required to act within a reasonable time. A delay of 13 years in reopening a final assessment was treated as inordinate and inconsistent with the finality of assessment proceedings. The court held that such stale revision could not be used to unsettle completed matters, and the revisional notice was quashed.

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Issues: Whether the suo motu revisional power under section 21(1) of the Punjab General Sales Tax Act, 1948 could be exercised after a delay of 13 years to reopen a final assessment.

Analysis: The Act did not prescribe a specific limitation period for suo motu revision, but the absence of an express time-limit did not permit reopening matters that had attained finality after an inordinate lapse of time. The revisional power had to be exercised within a reasonable period, and what constituted reasonable time depended on the facts of each case. A substantial delay in initiating revision could vitiate the proceedings, particularly where the assessment had long since become final.

Conclusion: The revisional notice issued after 13 years was not within a reasonable time and was liable to be quashed in favour of the petitioner.

Final Conclusion: The assessment could not be reopened through suo motu revision after such an inordinate delay, and the impugned notice was set aside.

Ratio Decidendi: Even where no express limitation is prescribed for suo motu revision, the revisional authority must act within a reasonable time, and an unreasonable delay that unsettles a final assessment invalidates the exercise of that power.

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