Limitation for rectification and revision under sales tax law must be strictly observed, including completion of revisional proceedings in time.

Section 33 of the Haryana General Sales Tax Act, 1973 permits rectification only within two years, so a belated rectification request is time-barred. Section 40(1) allows revisional action by the Commissioner, but the proviso bars revision after five years from the order date, and the revision must also conclude within that period; mere initiation in time is insufficient if the final revisional order is delayed beyond limitation. Section 41 also empowers the Tribunal to review an order suffering from patent errors of law, including an erroneous view on limitation for revision. On that basis, the review was maintainable and the order allowing review and rejecting the assessee's appeal was upheld.

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Issues: Whether the rectification application and the revisional proceedings were barred by limitation, and whether the Tribunal rightly exercised review jurisdiction to recall its earlier order.

Analysis: Section 33 of the Haryana General Sales Tax Act, 1973 permits rectification of clerical or arithmetical mistakes within two years from the date of the order. The assessee's rectification request was made after expiry of that period and was therefore time-barred. Section 40(1) of the Haryana General Sales Tax Act, 1973 empowers revision by the Commissioner, but the proviso bars revision after five years from the date of the order, and the revisional proceedings must culminate within that period. The Court applied the settled interpretation that mere initiation of revision within time is not enough if the final revisional order is passed after limitation. The Tribunal also had power under Section 41 of the Haryana General Sales Tax Act, 1973 to review an order suffering from patent errors of law, including the erroneous view that the assessee could invoke revision and that revision need not conclude within five years.

Conclusion: The limitation objections were rejected, the review was held maintainable, and the Tribunal's order allowing review and dismissing the assessee's appeal was upheld.

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