Amended limitation applies to pending revision proceedings where no vested right had accrued under the earlier time limit.

Amended limitation periods are ordinarily procedural and apply to pending revisional proceedings unless a vested right has already accrued under the earlier limit. Applying that principle, the amended time limit in section 67(1)(a) of the Gujarat Sales Tax Act, 1969 governed a suo motu revision that was already pending when the amendment took effect, even though the revision notice had been issued earlier and the revisional order was passed later. The Tribunal was therefore not justified in holding that the unamended limitation continued to apply.

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Issues: Whether the amended limitation in section 67(1)(a) of the Gujarat Sales Tax Act, 1969 applied to revisional proceedings that were already pending when the amendment came into force.

Analysis: The revision notice had been issued before the amendment, but the revisional order was passed after the amended provision came into force. The Court applied the settled principle that a change in limitation is ordinarily procedural and therefore governs pending proceedings unless a vested right has already accrued by expiry of the earlier limitation. On that basis, the amended time limit for passing the revisional order was held applicable to the pending suo motu revision proceedings.

Conclusion: The amended section 67(1)(a) applied to the pending proceedings, and the Tribunal was not justified in holding otherwise.

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