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Issues: Whether the revisional power of the Deputy Commissioner under Section 15 of the General Sales Tax Act, 1125 could be exercised after the expiry of the period prescribed by Rule 33 of the General Sales Tax Rules, 1950 in respect of escaped turnover.
Analysis: The revisional power under Section 15 was held to be exercisable only within the same time limit within which the Sales Tax Officer could have acted under Rule 33 in matters relating to escaped turnover. The Court read the revisional authority's power as subject to the limitation built into Rule 33, and reasoned that once three years from the end of the assessment year had expired, the assessing authority itself could no longer proceed under that rule. The restriction was confined to escaped turnover cases and did not extend beyond the scope of Rule 33.
Conclusion: The revisional order made after the expiry of three years from the end of the assessment year was without authority and could not stand.
Final Conclusion: The tax revision case was allowed, and the revisional action was held to be time-barred in relation to escaped turnover.
Ratio Decidendi: Where a revisional power is conferred in relation to escaped turnover, it is subject to the same statutory time limit that governs the original assessing authority's action under the corresponding escapement rule.