Revisional limitation under sales tax law applies to initiation only, not to the final order, under section 22-A.

Section 22-A of the Karnataka Sales Tax Act, 1957 was construed to require only that revisional proceedings be initiated, by calling for the records, within four years from the order sought to be revised. The Court treated calling for records, examination of those records, and passing of the revisional order as components of the same revisional power, but held that limitation attaches to commencement of that power, not its completion. The later insertion of section 22-B, which separately fixed a time limit for passing orders after initiation, was treated as confirming that section 22-A governs initiation only. The contrary view, that the final revisional order must also be made within four years, was rejected.

---

---

Issues: Whether, under section 22-A of the Karnataka Sales Tax Act, 1957, the period of four years governs only the initiation of revisional proceedings by calling for the records, or whether it also requires the final revisional order to be passed within that period.

Analysis: The revisional provision, as amended from time to time, used different formulations, but the controlling language in the relevant version restricted the exercise of revisional power to within four years from the date of the order sought to be revised. The Court treated calling for the records, examination of those records, and passing of the revisional order as facets of one revisional power, and held that limitation attaches to the commencement of that power. The later insertion of section 22-B, which separately prescribed a time limit for passing orders after initiation or calling for records, was taken as confirming that section 22-A was concerned with initiation, not completion, of the revision. The contrary view that the final order itself must be made within four years was rejected.

Conclusion: The four-year limitation under section 22-A applies only to initiation of the revisional proceedings by calling for the records, and not to the passing of the final revisional order. The answer is in favour of the Revenue.

Ratio Decidendi: Where a revisional statute makes the power exercisable within a stated period from the order sought to be revised, the limitation governs initiation of the revisional process and not necessarily the completion of the final order, unless the statute expressly so provides.

---