Limitation for sales tax revision runs from service on the State representative, not on the Deputy Commissioner.

For revision under section 38 of the Tamil Nadu General Sales Tax Act, limitation runs from service of the Appellate Tribunal's order on the State representative, because service on that representative is effective service on the State. Although section 36(8) also requires communication to the Deputy Commissioner and the Commissioner, that does not shift the limitation start date to service on the Deputy Commissioner. The Deputy Commissioner functions only as the State's agent for filing the revision, so the revision period must be computed from the date of service on the State representative. The challenge was therefore unsuccessful.

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Issues: Whether, for filing a revision under section 38 of the Tamil Nadu General Sales Tax Act, 1959, limitation runs from service of the Appellate Tribunal's order on the State representative or from service on the Deputy Commissioner.

Analysis: The statutory scheme treated the State of Tamil Nadu as the respondent in the appeal, with service on the State representative constituting effective service on the State. Though section 36(8) required the order to be communicated to the Deputy Commissioner and the Commissioner as well, that did not make the Deputy Commissioner the point of commencement for limitation. Section 38 identified the Deputy Commissioner as the officer through whom the State acts for filing revision, but he remained only the State's agent for that purpose. The time for revision therefore had to be computed from the date on which the copy of the order was served on the State representative, who was responsible for co-ordinating with the Deputy Commissioner.

Conclusion: Limitation for revision under section 38 begins from service on the State representative, not from service on the Deputy Commissioner. The challenge failed.

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