Reasonable-time limit on revisional power requires clear jurisdiction before reopening a concluded assessment.

Section 34 confers wide revisional power without a fixed limitation period, but the power must still be exercised bona fide and within a reasonable time. A completed assessment cannot be reopened after long delay unless cogent reasons justify the lapse, especially where escaped assessment and rectification provisions may be the proper route. The authority must also identify the correct jurisdictional basis before proceeding. Here, the revisional order did not properly address either the delay or the source of power, so the matter required fresh consideration and reconsideration in accordance with law.

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Issues: (i) whether the Commissioner could exercise suo motu revisional power under section 34 after a long lapse of time in the absence of an express limitation period, and (ii) whether the revisional authority had correctly addressed the nature of the alleged escapement and the proper source of power for reopening the assessment.

Issue (i): whether the Commissioner could exercise suo motu revisional power under section 34 after a long lapse of time in the absence of an express limitation period.

Analysis: Section 34 confers wide revisional power and does not prescribe a fixed period of limitation, but such statutory power must still be exercised bona fide, reasonably, and within a reasonable period. Where a completed assessment is sought to be reopened after the normal periods contemplated by the provisions relating to escaped assessment and rectification, cogent and sufficient reasons must exist to justify the delay. The facts showed that the notice and revisional order were issued many years after the assessment had attained finality, and the authority did not properly address the objection that the action was not initiated within a reasonable time.

Conclusion: The issue was not finally answered on merits by the revisional authority, and the matter required fresh consideration on the question of reasonable time.

Issue (ii): whether the revisional authority had correctly addressed the nature of the alleged escapement and the proper source of power for reopening the assessment.

Analysis: The record indicated uncertainty as to whether the case was one of escapement of income or one fit for revision under section 34. The scheme of the Act distinguishes between escaped assessment and rectification on the one hand, and revisional supervision on the other, and the authority was required to identify the correct jurisdiction before proceeding. Since that jurisdictional question was not clearly analysed or decided in the revisional order, the reference could not be answered conclusively.

Conclusion: The issue remained unresolved and had to be reconsidered by the Commissioner in accordance with law.

Final Conclusion: The reference was not decided on the substantive question of limitation or jurisdiction, and the revisional proceedings were sent back for fresh disposal in the light of the court's observations.

Ratio Decidendi: Where a statute confers revisional power without prescribing a limitation period, the power must nevertheless be exercised within a reasonable time, and the authority must first determine the correct jurisdictional basis before reopening a concluded assessment.

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