Suo motu revisional power requires exceptional supervening reasons and reasonable promptness; inordinate delay vitiates proceedings and they were set aside.

Suo motu revisional proceedings under section 34 were assessed against the temporal limits and purpose of statutory revision/rectification provisions, with the court applying the Limitation Principle that normally the outer limit for initiating suo motu revision aligns with the periods contemplated for reopening. Reopening beyond those periods requires cogent, demonstrable supervening events or exceptional difficulties and a bona fide, reasonable exercise of power. Absent material showing such exceptional circumstances, the long lapse rendered the revisional exercise unreasonable; the proceedings dated March 30, 1991, in respect of the earlier assessments were therefore vitiated and set aside in favour of the assessees.

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Issues: Whether the suo motu revisional proceedings under section 34 of the Act, revising assessments for assessment years 1981-82 to 1984-85, were initiated within a reasonable time or are vitiated by inordinate delay.

Analysis: The Court examined whether the normal periods for reopening assessments under the statutory provisions governing revision and rectification (as reflected in sections 35 and 36 of the Act) set the outer limits for initiating suo motu revision under section 34, and whether reopening beyond those periods is permissible only upon demonstration of cogent and sufficient reasons. The Court applied the test that reopening by the Revenue after the periods contemplated by sections 35 or 36 demands circumstances beyond control, supervening events, or other exceptional difficulties that prevented initiation within the normal period, and that the revisional power must be exercised bona fide within a reasonable period. The revisional authority had repelled the delay objection but no material or record was produced to show any supervening events or cogent reasons justifying initiation of suo motu revisional proceedings long after the limitation periods had expired. The Court relied on the benchmark that normally the period for suo motu revision should not exceed the periods fixed under sections 35 or 36, and that absent demonstrable exceptional circumstances the long lapse of years renders the exercise of revisional power unreasonable.

Conclusion: The suo motu revisional proceedings dated March 30, 1991, in respect of the assessments for the years 1981-82 to 1984-85 are vitiated by inordinate delay and are set aside; the tax revision cases are allowed in favour of the assessees.

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