Backdated revisional orders cannot defeat statutory limitation and are invalid when the record shows delayed passing.

A revisional order dated within the four-year limitation under Section 22A(4) of the Karnataka Sales Tax Act, 1957 was found to be unsupported by the record, because the assessee's reply was received later and dispatch occurred much later. The mismatch between the stated date and the procedural sequence showed that the order had been backdated to bring it within limitation. An order actually passed after expiry of the statutory period but ante-dated to appear timely is invalid and liable to be quashed for circumvention of limitation.

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Issues: Whether the revisional order was barred by limitation and liable to be quashed as an ante-dated order passed to circumvent the statutory limitation period.

Analysis: The impugned revisional order was shown as dated before expiry of the four-year limitation under Section 22A(4) of the Karnataka Sales Tax Act, 1957, but the record disclosed that the assessee's reply had in fact been received later and the order was dispatched only much later. The date mentioned on the order could not be reconciled with the record, and the sequence of events established that the order had been backdated to bring it within limitation.

Conclusion: The revisional order was held to be ante-dated, passed after expiry of the statutory limitation, and therefore quashed in favour of the assessee.

Final Conclusion: The appeals were allowed and the impugned revisional order was set aside with exemplary costs.

Ratio Decidendi: An order of revision that is actually passed after the statutory limitation period but is backdated to appear within time is invalid and liable to be quashed for circumvention of limitation.

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