Reasonable period limits on suo motu revision barred a delayed notice issued after years of unexplained inaction.

Revisional power under the Punjab General Sales Tax Act, 1948, though not subject to an express limitation in section 21(1), must be exercised within a reasonable period. A suo motu revision notice issued after more than seven years was found unsustainable because the delay was substantial, remained unexplained, and the stated basis for revision did not justify the lapse of time. The notice was therefore barred by delay and was set aside.

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Issues: Whether the notice for suo motu revision of assessment issued after more than seven years was liable to be quashed as being beyond a reasonable period under the Punjab General Sales Tax Act, 1948.

Analysis: Section 21(1) of the Act does not prescribe an express limitation for revisional action, but such power must still be exercised within a reasonable period. The Court applied the governing principle that, even where no specific period is stated, statutory powers cannot be exercised indefinitely and delay must be judged in the light of the statutory scheme and the nature of the power. The delay in issuing the revision notice was substantial, the delay was not explained, and the ground on which revision was proposed did not cure the lapse of time. On these facts, the notice could not be sustained.

Conclusion: The notice was barred by delay and was rightly set aside in favour of the petitioner.

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