Limitation Act applies to VAT revision delay, and rusk is commercially distinct from bread for exemption purposes.

A special tax statute's revision period may attract the Limitation Act, 1963 where the statute prescribes a filing limit but does not expressly exclude condonation; read with Section 29(2), Sections 3 to 24 can apply, and delay may be condoned on sufficient cause. On the stated facts, the mistaken approach to another forum was treated as bona fide, so the revisional delay was condoned. For VAT classification, rusk was treated as a commercially distinct commodity from bread because it undergoes further manufacture and value addition; the exemption available to bread therefore did not extend to rusk, and the exemption denial was left undisturbed.

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Issues: (i) Whether the revisional delay under Section 70 of the Meghalaya Value Added Tax Act, 2003 could be condoned by applying the Limitation Act, 1963; (ii) Whether rusk is liable to be treated as bread and exempt from VAT.

Issue (i): Whether the revisional delay under Section 70 of the Meghalaya Value Added Tax Act, 2003 could be condoned by applying the Limitation Act, 1963.

Analysis: Section 70 prescribed a 60-day period for filing a revision, but it neither expressly conferred nor expressly excluded power to condone delay. Read with Section 29(2) of the Limitation Act, 1963, the absence of express exclusion did not bar application of Sections 3 to 24 of that Act. Section 110 of the Meghalaya Value Added Tax Act, 2003 was confined to Chapter VI and did not control revisions under Chapter VII. On the facts, the delay was held to be supported by sufficient cause and the earlier mistaken invocation of another forum was treated as bona fide.

Conclusion: The delay in filing the revision was condonable and was condoned.

Issue (ii): Whether rusk is liable to be treated as bread and exempt from VAT.

Analysis: The product manufactured was not ordinary bread but bread subjected to a further process of manufacture into rusk. Applying the common parlance test, bread and rusk are commercially distinct commodities. The reasoning was aligned with the principle that a product emerging after additional processing and value addition is not necessarily the same as its raw or intermediate form for tax exemption purposes.

Conclusion: Rusk was not treated as bread and the exemption available to bread was not extended to rusk.

Final Conclusion: The revisional challenge failed on merits, and the appellate order denying VAT exemption to rusk was left undisturbed.

Ratio Decidendi: Where a special tax statute does not expressly exclude the Limitation Act, 1963, revisional delay may be condoned under Section 29(2) if sufficient cause is shown; and for sales tax or VAT classification, a commodity subjected to further manufacture and commercially known as a distinct product is not entitled to exemption merely because it originates from an exempt raw material.

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