Extended limitation under tax law applies only when revision directly gives effect to a court direction, not a mere objection-filing order.

Section 24-A of the Andhra Pradesh General Sales Tax Act, 1957 applies only when a later assessment or revision is made in pursuance of, in consequence of, or to give effect to a court finding or direction. A writ order that merely required the dealer to file objections to a show-cause notice and have them considered on merits did not trigger the extended limitation period, especially where the revisional proceedings had already begun before the writ petition. The revision was therefore governed by the ordinary limitation under section 20 and, even after excluding the writ period, remained time-barred.

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Issues: Whether the revisional order was barred by limitation, and whether the extended limitation under section 24-A of the Andhra Pradesh General Sales Tax Act, 1957 applied because the revision was made in pursuance of, in consequence of, or to give effect to the High Court's earlier order.

Analysis: Section 24-A applies only where the later assessment or revision is made in pursuance of, in consequence of, or to give effect to a finding or direction contained in an of a court. The earlier writ order merely directed the dealer to file objections to the show-cause notice and to have them considered on merits; it did not itself direct the revisional order or supply any finding requiring such revision. The revisional proceedings had already commenced before the writ petition, and the impugned order could not therefore be treated as one passed in consequence of the court's order. In the absence of section 24-A, the ordinary limitation under section 20 governed the revision, and even after excluding the period during which the writ proceedings were pending, the order dated April 11, 1990 was still beyond the permissible time.

Conclusion: The extended limitation under section 24-A was inapplicable, and the revisional order was time-barred under section 20.

Final Conclusion: The special appeals succeeded because the impugned revisional order was passed beyond limitation and could not be sustained.

Ratio Decidendi: An order can fall within the extended limitation provision only when it is made in direct pursuance of, in consequence of, or to give effect to a court's finding or direction; a mere direction to file objections to a notice does not attract the extended period.

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