Binding precedent and limitation in revision govern tax disputes, while unreasoned condonation of delay cannot sustain appellate orders.

A revisional authority must follow an earlier Supreme Court ruling governing the same tax dispute and cannot displace it by relying on a later decision concerning a different entry. A blanket, unreasoned condonation of substantial delay is unsustainable because sufficient cause must be examined on the record; orders passed after such condonation may fail, and some matters require fresh consideration of delay. Revisional power must also be exercised within the statutory four-year period, counted up to the passing of the revisional order, and revision beyond that limit is time-barred. The discussion emphasises binding precedent, reasoned delay condonation, and strict limitation in revision.

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Issues: (i) whether the revisional authority could ignore the binding effect of the earlier Supreme Court ruling on taxability of wires drawn from tax-suffered wire rods and sustain the revision on the basis of a later decision on a different entry; (ii) whether the appellate authority's blanket condonation of long delay and consequent orders on merits were sustainable; and (iii) whether the revisional order was barred by the period of limitation under the revisional provision.

Issue (i): whether the revisional authority could ignore the binding effect of the earlier Supreme Court ruling on taxability of wires drawn from tax-suffered wire rods and sustain the revision on the basis of a later decision on a different entry.

Analysis: The earlier Supreme Court decision directly governed the same entry and the same tax dispute, and the revisional authority was bound to follow it unless it was specifically overruled. A later ruling concerning a different entry could not be treated as displacing the binding force of the earlier decision inter partes. Ignoring the earlier ruling would be inconsistent with the constitutional command that the law declared by the Supreme Court is binding.

Conclusion: The revisional authority was not justified in displacing the earlier Supreme Court ruling on the ground that it had been shaken by a later decision; that ground of revision failed.

Issue (ii): whether the appellate authority's blanket condonation of long delay and consequent orders on merits were sustainable.

Analysis: Condonation of a substantial delay required a reasoned judicial determination on sufficient cause. A cryptic order merely stating that delay was condoned and appeal admitted did not show application of mind to the explanation for delay, the surrounding circumstances, or the effect of the alleged passing on of tax. Such an order was arbitrary and could not support the merits disposal that followed. In the appeals where the delay was wholly unexplained and the conduct was not bona fide, the condonation itself was impermissible.

Conclusion: The appellate orders were unsustainable where delay had been condoned without reasons; in the older assessment years, the delay ought to have been rejected and the Commissioner was justified in revising those orders, while in the other batch the matters required de novo consideration.

Issue (iii): whether the revisional order was barred by the period of limitation under the revisional provision.

Analysis: The revisional power under the Act was exercisable only within the prescribed period of four years, and the order of revision had been passed beyond that period counted from service of the appellate order. The Court declined to depart from its earlier view that the limitation governed the passing of the final revisional order, not merely the initiation of proceedings. The statutory language and the need to prevent indefinite prolongation of revision supported that construction.

Conclusion: The revisions in the time-barred batch were barred by limitation and could not be sustained.

Final Conclusion: The batch was disposed of partly in favour of the assessee: some revisional orders were set aside for limitation, some appeals succeeded because the revision could not survive, and the remaining matters were remitted for fresh consideration of delay condonation in accordance with law.

Ratio Decidendi: A revisional authority must act within the statutory time-limit, must adhere to binding precedent governing the very dispute, and cannot sustain an appellate order founded on unreasoned condonation of inordinate delay.

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