Revisional jurisdiction after repeal fails where the saving clause preserves only pending proceedings, not fresh revision notices.

Section 61 of the Haryana Value Added Tax Act, 2003 preserved only proceedings pending when the new Act commenced, so revision under Section 40 of the repealed Haryana General Sales Tax Act, 1973 could not be initiated after repeal unless specifically saved. Section 61(2)(d) was confined to tax concessions for industrial units under Sections 13B and 25A and related rules; it did not preserve or confer power to start revisional proceedings, nor did it cover pending revisions for that purpose. The impugned revisional action was therefore without jurisdiction.

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Issues: Whether revisional proceedings under Section 40 of the repealed Haryana General Sales Tax Act, 1973 could be initiated after the Haryana Value Added Tax Act, 2003 came into force, and whether Section 61(2)(d) of the Haryana Value Added Tax Act, 2003 saved such revisional action.

Analysis: The repeal and saving clause in Section 61 of the Haryana Value Added Tax Act, 2003 preserved only proceedings that were already pending on the date of commencement of the new Act. The revisional notice and the order in the present case were issued after the repeal of the 1973 Act, and therefore the revisional authority lacked jurisdiction unless the case was covered by a specific saving provision. Section 61(2)(d) dealt with tax concessions to industrial units under Sections 13B and 25A of the 1973 Act and the related rules. It did not confer or preserve any power to initiate revision proceedings under Section 40, nor did it refer to pending applications, appeals, or revisions for that purpose.

Conclusion: The revision proceedings were without jurisdiction and the assessee succeeded. Section 61(2)(d) did not save the impugned revisional action.

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