Plenary revisional power under sales tax law and conflict on limitation sent for larger Bench resolution.

Section 21(1) of the Punjab General Sales Tax Act was considered to confer plenary revisional power, and earlier authority held that no limitation could be imported from the reassessment provision in section 11-A. A later contrary view had not addressed that earlier decision, creating conflicting interpretations on whether suo motu revision remained available after reassessment became time-barred and whether a subsequent change in legal position could justify revision. The Court therefore did not decide the merits itself and referred the question of law to a larger Bench for authoritative resolution.

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Issues: Whether the revisional authority could invoke suo motu revisional power under section 21(1) of the Punjab General Sales Tax Act, 1948 after the reassessment remedy under section 11-A had become time-barred, and whether the conflict between earlier and later decisions on the scope of section 21(1) required resolution by a larger Bench.

Analysis: The Court noticed that earlier authorities had held that section 21(1) confers plenary revisional powers and that no period of limitation can be read into it by reference to section 11-A. It also noted that later authority taking a contrary view had not considered the directly applicable earlier decision. In view of the conflicting views on whether a subsequent change in the legal position can support revisional action under section 21(1), the Court found it appropriate to seek an authoritative resolution by a larger Bench.

Outcome: The question of law was referred to a larger Bench for decision.

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