Limitation for revision runs from actual or constructive notice of the order, preserving the assessee's remedial right.

For revision under section 33A, the phrase "from the date of the order" is read in a practical sense so the remedial right is not defeated by delayed communication or non-promulgation. Limitation starts only when the assessee has actual or constructive notice of the order, because a revision remedy can be effectively exercised only when the affected party knows, or is deemed to know, of it. On that basis, the revision application was within time.

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Issues: Whether, for an application for revision under section 33A, limitation runs from the date of the order itself or from the date when the assessee had actual or constructive notice of the order.

Analysis: The expression "from the date of the order" was construed in a practical and effective sense so that the statutory right of revision is not defeated by the delayed communication or non-promulgation of the order. A limitation period attached to a remedial right must be meaningful to the person affected, and it cannot be cut down by the mere unilateral act of the authority passing the order without the party's knowledge. The Court held that the word "order" in this context refers to an order of which the affected party has actual or constructive notice, since the right of revision can be exercised effectively only when the party knows, or is deemed to know, of the order.

Conclusion: Limitation under section 33A begins to run only when the assessee has actual or constructive knowledge of the order, not merely from the date on which the order was passed; the revision application was therefore within time and the assessee succeeded.

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