Reasonable time limits on revisional power bar a notice issued more than 20 years after assessment under sales tax law.

Revisional power under Section 21(1) of the Punjab General Sales Tax Act, 1948, though not subject to an express limitation period, must be exercised within a reasonable time. Applying the settled principle that open-ended statutory revisional jurisdiction cannot be used after an indefinite delay, the Court treated a period beyond five years as ordinarily excessive. A notice issued more than 20 years after the assessment order was therefore far beyond any reasonable period and was unsustainable; the notice was invalid and the writ petition was allowed.

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Issues: Whether a revisional notice under Section 21(1) of the Punjab General Sales Tax Act, 1948 could be sustained when issued more than 20 years after the assessment order.

Analysis: The revisional power under Section 21(1) contains no express limitation period, but it must still be exercised within a reasonable time. The controlling principle applied was that where no period is prescribed, statutory power cannot be used at any time and must be confined to a reasonable period. The Court relied on the settled view that revisional jurisdiction ordinarily should not exceed five years, and held that a notice issued after more than 20 years was far beyond any reasonable period. The delay itself rendered the action unsustainable.

Conclusion: The notice was invalid and liable to be set aside; the writ petition was allowed in favour of the petitioner.

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