Revisional jurisdiction survives expiry of limitation when proceedings were started in time and may be concluded on merits.

Where revisional proceedings are initiated within the prescribed one-year limitation under section 34, expiry of that period does not extinguish the Commissioner's revisional jurisdiction or make the authority functus officio. The limitation governs the commencement of revision, not its final disposal, and the proceedings may be completed on the merits after the period has elapsed if they were validly instituted in time. Applying that principle, the dismissal of the revision was set aside and the matter was restored for fresh decision on the merits.

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Issues: Whether the Commissioner's revisional jurisdiction under section 34 could be exercised after the expiry of one year when the assessee's revision application had been filed within time.

Analysis: Section 34 prescribed a period of one year as a limitation for invoking revision, but the governing question was the date on which the revisional proceedings were commenced, not the date on which they were finally disposed of. Once jurisdiction was validly invoked within the prescribed period, the expiry of that period did not extinguish the revisional power or render the Commissioner functus officio. The distinction drawn in the analogous income-tax revisional provisions supported the view that the limitation operated upon initiation of proceedings and not upon their completion.

Conclusion: The Commissioner was not barred from disposing of the revision on the merits after the one-year period had elapsed, provided the revision had been instituted within time.

Final Conclusion: The dismissal of the revision by the Commissioner was set aside and the matter was restored for fresh decision on the merits.

Ratio Decidendi: Where revisional proceedings are initiated within the prescribed limitation period, expiry of that period does not terminate the revisional jurisdiction, and the authority may complete the proceedings thereafter.

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