Revisional jurisdiction under VAT law was unavailable against a rectification order, and no question of law arose.

Revision under section 48(1) of the Himachal Pradesh Value Added Tax Act, 2005 lay only against Tribunal orders passed under section 45(2) or section 46(3), and only where a timely application disclosed an erroneous decision of law or failure to decide a question of law. A Tribunal rectification order under section 47(1) was not revisable under that provision, and the attack on the original Tribunal order was time-barred. No question of law arose on the facts, so revisional jurisdiction could not be invoked and the revision was not maintainable.

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Issues: Whether a revision under section 48(1) of the Himachal Pradesh Value Added Tax Act, 2005 lay against the Tribunal's rectification order under section 47(1) and the earlier Tribunal order, and whether any question of law arose for revisional interference.

Analysis: Section 48(1) permits revision only against orders of the Tribunal passed under section 45(2) or section 46(3), and only where the application is within limitation and a question of law arising from an erroneous decision of law or failure to decide a question of law is shown. The impugned rectification order was not an order amenable to revision under section 48(1). The challenge to the original Tribunal order was also barred by limitation. On the facts, no question of law arose for consideration and the revisional jurisdiction could not be invoked.

Conclusion: The revision was not maintainable and the challenge failed.

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