Limitation for revisional power is met when the final order is passed in time; later service does not invalidate revision.

Under section 20(3), the limitation period is satisfied when the revisional authority passes the final revisional order within four years; later service of that order is only a ministerial act and does not invalidate an order made in time. The Court distinguished authority relied on by the assessee because that case involved unexplained delay, whereas the service delay here was explained. The revisional order was therefore held to be within limitation, the challenge failed, and no relief was available to the assessee.

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Issues: Whether the four-year period prescribed for exercise of revisional power under section 20(3) includes service of the final revisional order, or is satisfied once the order is passed within that period.

Analysis: The Court held that the statutory limit under section 20(3) governs the exercise of revisional power and the passing of the final order, not the later ministerial act of service. It distinguished the case relied on by the assessee on the ground that there was an unexplained delay there, whereas here the delay in service was explained and treated as ministerial. The Court followed the consistent line of authority that communication of the order after expiry of four years does not invalidate a revision order already made within time.

Conclusion: The revisional order was within limitation because it was passed within four years of the order sought to be revised. The delay in service did not vitiate the order, and the challenge failed.

Final Conclusion: The revision was valid in law and the assessee was not entitled to relief.

Ratio Decidendi: For the purpose of section 20(3), limitation is satisfied when the revisional authority passes the final order within the prescribed period; subsequent service of that order is only a ministerial act and does not affect validity if the order was in fact made in time.

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