Reasonable time limits on suo motu revision under sales tax law bar unexplained action after more than six years.

A revisional power conferred without an express limitation period must still be exercised within a reasonable time. Applying the settled approach under the Punjab General Sales Tax Act, the Court treated revisional jurisdiction as ordinarily confined to three years and, in any event, not beyond five years. Because the department acted after more than six years, despite the relevant legal position being known earlier and no justification for delay being shown, the revisional action was beyond a reasonable period and unsustainable; the reassessment was restored and the revisional orders were set aside.

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Issues: Whether the suo motu revisional power under section 21(1) of the Punjab General Sales Tax Act, 1948 could be exercised after more than six years from the original assessment, and whether such exercise was within a reasonable period.

Analysis: Section 21(1) confers revisional power without prescribing any express limitation, but such power must still be exercised within a reasonable period. The Court applied the settled principle that reasonableness depends on the statutory scheme and relevant circumstances, and relied on the controlling view that revisional jurisdiction under the Act should ordinarily be exercised within three years and in any event should not exceed five years. In the present case, the reassessment was sought after more than six years on a ground already known to the department when the relevant legal position emerged, and no justification was shown for the delay.

Conclusion: The revisional authority was not justified in invoking section 21(1) after more than six years, and the revisional action was beyond a reasonable period.

Final Conclusion: The reassessment was restored and the revisional orders were set aside because the exercise of suo motu revision was time-barred in substance for want of action within a reasonable period.

Ratio Decidendi: Where a revisional power is conferred without an express limitation period, it must nevertheless be exercised within a reasonable time, and unexplained delay beyond the ordinarily acceptable period renders the revision unsustainable.

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