Limitation under customs revision rules can defeat jurisdiction when the application is filed beyond the maximum condonable period.

Section 129-DD of the Customs Act permits revision within three months of communication of the order, with a further three-month extension only on sufficient cause. Where the revision application was filed after expiry of even the maximum condonable period, the revisional authority lacked competence to entertain it or condone delay, and the revisional order was without jurisdiction. A prior writ decision did not bar the challenge because the present limitation-based jurisdictional objection had not been examined there. The revisional order was quashed, and the consequential refund direction was sustained.

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Issues: Whether the revisional order under Section 129-DD of the Customs Act was jurisdiction for having been made after expiry of the maximum condonable period, and whether the consequential penalty order could be quashed.

Analysis: The statutory scheme under Section 129-DD permits revision by the Central Government within three months from communication of the order, with a further discretionary extension of three months on sufficient cause. On the admitted facts, the revision was presented only after expiry of even the condonable period. Once the application itself was beyond the outer limit prescribed by the statute, the revisional authority had no competence to entertain it or to condone the delay. The challenge based on the earlier writ decision was not accepted, as the present jurisdictional objection under limitation had not been examined there.

Conclusion: The revisional order was without jurisdiction and was liable to be quashed. The writ petition was allowed, and the consequential direction for refund of the deposited amount followed.

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