Time-bar on revisional power prevents reopening of refund orders once the statutory limit has expired.

The statutory revisional power was time-bound, and a refund order passed under the Act could not be reopened once the prescribed period had expired. Under the Andhra Pradesh General Sales Tax Act, 1957, the four-year limit under section 20(3) ran from service of the original order on the dealer. As the refund orders were passed in 1992 and the revisional notices were issued only in 1999, the revision was beyond limitation. The Tribunal was therefore correct in setting aside the Deputy Commissioner's revisional order.

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Issues: Whether the revisional order passed by the Deputy Commissioner revising the refund granted under Rule 27-A was barred by limitation and whether the Tribunal was justified in setting aside that order.

Analysis: The refund orders were passed in 1992, while the show-cause notices proposing revision were issued in 1999. Section 20(3) of the Andhra Pradesh General Sales Tax Act, 1957 limits the exercise of revisional power to a period not exceeding four years from the date on which the order was served on the dealer. The power of revision under the Act extends to orders passed under the Act, including refund orders granted under the Rules. Since the revisional notices and the consequent order were issued well beyond the prescribed period, the revision was beyond limitation. The Tribunal's view was therefore consistent with the statutory scheme.

Conclusion: The revisional order was barred by limitation and the Tribunal was correct in setting it aside.

Ratio Decidendi: The statutory revisional power is time-bound, and where the prescribed period has expired, a refund order passed under the Act cannot be reopened by revision.

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