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Issues: Whether the sales tax revision was barred by limitation under section 33(1) of the Himachal Pradesh General Sales Tax Act, 1968 and whether the delay could be condoned under section 5 of the Limitation Act, 1963.
Analysis: Section 33(1) prescribed a specific period of limitation of 60 days for a sales tax revision. The statute itself was treated as a complete code on the point of limitation, and the general power of condonation under section 5 of the Limitation Act was held not to enlarge that period. The revision had been filed beyond the prescribed time and, therefore, could not be entertained.
Conclusion: The revision was barred by limitation and the delay was not condonable. The proceeding was dismissed in favour of the assessee.
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