Limitation for assessment orders runs from signing, not communication, where the statute uses "made" as the operative date.

The expression "made" in Section 126(4) of the Delhi Municipal Corporation Act, 1957 was interpreted to mean the date on which the assessment order is signed and passed, not the date on which it is communicated to the assessee. The limitation period for the Commissioner's power to amend the assessment list runs from the relevant statutory date when the order becomes final and operative, unless the statute makes communication itself a condition. The Court distinguished cases where communication affects the availability of a remedy and applied the presumption that official acts are regularly and bona fide performed. The contrary view was held unsustainable.

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Issues: Whether the word "made" in Section 126(4) of the Delhi Municipal Corporation Act, 1957 means the date on which the assessment order is signed and passed, or the date on which it is communicated to the assessee.

Analysis: The limitation under Section 126(4) restricts the statutory power of the Commissioner to amend the assessment list within three years from the end of the year in which notice is given. The expression "made" was construed in its ordinary and contextual sense, distinct from "communicated". The Court held that when a statutory authority exercises power within a prescribed period of limitation, the relevant date is the date on which the order is signed and ceases to be alterable, not the date of communication to the affected party. The Court distinguished authorities where communication is necessary to trigger a remedy or affect rights after the decision, and applied the presumption that official acts are regularly and bona fide performed.

Conclusion: "Made" in Section 126(4) means the date on which the order is signed and passed, not the date of communication; the High Court's contrary view was and could not be sustained.

Final Conclusion: The assessment order was within time if counted from the date it was signed, and the appellate order treating communication as the relevant date was set aside.

Ratio Decidendi: Where a statutory provision prescribes a time limit for an authority to exercise power and make an order, the order is made when it is signed or otherwise becomes operative, and not when it is communicated to the affected party, unless the statute makes communication the relevant condition.

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