Limitation barred show cause notice: delayed issuance and consequential order were quashed, with review delay condoned.

A show cause notice issued after the prescribed six-month limitation period was held time-barred, and the consequential order was invalid as well. The Court accepted that the amended provisions relied on by the Revenue did not apply because the Central Government had already passed the final order earlier. It also condoned the delay in seeking review and recalled the earlier direction requiring the petitioner to pursue limitation before the Tribunal. The notice and consequential order were quashed on limitation grounds.

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Issues: Whether the show cause notice and the consequential order were barred by limitation and liable to be quashed.

Analysis: The notice was issued beyond the prescribed six-month period from the date of the Appellate Collector's order. The Court accepted that the amended provisions relied upon by the Revenue did not govern the matter because the Central Government had already passed the final order earlier. The Court further held that the delay in seeking review deserved to be condoned and that the earlier view directing the petitioner to pursue limitation before the Tribunal required recall.

Conclusion: The show cause notice was time-barred, illegal, and the consequential order was also invalid; the petitioner succeeded on limitation.

Final Conclusion: The review was allowed, the delay was condoned, and the impugned notice and consequential order were quashed on the ground of limitation.

Ratio Decidendi: A show cause notice issued beyond the prescribed limitation period is void, and any order made in consequence thereof is likewise liable to be set aside.

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