Revision limitation runs to initiation, not final disposal, where a taxing statute uses "revise" in a composite revisional scheme.

Section 34(2)(c) of the Tamil Nadu Agricultural Income-tax Act, 1955 was construed to limit only the initiation of revisional proceedings, not the passing of the final revisional order. The word "revise" was read as covering the full revisional process, including calling for records, enquiry and decision, so a revision filed within three years remained valid even if disposed of later. This interpretation preserved the workability of the revisional machinery and avoided making the assessee's remedy depend on administrative delay. The return of the revision petitions was therefore unsustainable, and they had to be entertained and decided on merits.

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Issues: Whether the three-year limit in section 34(2)(c) of the Tamil Nadu Agricultural Income-tax Act, 1955 governed only the initiation of revision proceedings or also required final disposal within that period.

Analysis: The provision conferred revisional power both suo motu and on application by an assessee. The word "revise" was held to denote the entire revisional process, including calling for records, enquiry and passing of orders, and not merely the final act of disposal. A construction limiting only the final order would make the remedy depend on the pace of the revisional authority and could defeat a timely application by the assessee. The interpretation adopted was required to preserve the workability of the machinery provision and to harmonise the provision with the scheme of the Act.

Conclusion: The three-year period applies to the initiation of revisional proceedings, not to the passing of the final revisional order, and a revision filed within time may be disposed of later.

Final Conclusion: The return of the revision petitions was unsustainable and the petitions had to be entertained and decided on merits.

Ratio Decidendi: Where a taxing statute uses "revise" in a composite revisional scheme, limitation is satisfied if the revisional jurisdiction is validly invoked within time, and the final order may follow thereafter unless the statute expressly requires completion within the same period.

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