Reasonable time limits govern suo motu revisional power; unexplained delay can invalidate a notice and justify writ review.

A revisional power under the Punjab General Sales Tax Act, though not subject to an express limitation period, must still be exercised within a reasonable time drawn from the statutory scheme and surrounding provisions. The Court held that the assessment framework indicated that revision should ordinarily be taken within three years and in any event not beyond five years. A revisional notice issued after about 51/2 years, without reasons, was therefore beyond a reasonable period and vulnerable to judicial review; the writ petition challenging it on limitation grounds was maintainable.

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Issues: Whether suo motu revisional power under the Punjab General Sales Tax Act could be exercised after an unreasonable delay and whether the writ petition challenging the notice on limitation was maintainable.

Analysis: No express period of limitation was prescribed for exercise of revisional power, but a statutory authority cannot act at any time merely because the provision is silent. The reasonable period must be gathered from the statutory scheme, the nature of rights and liabilities, and relevant surrounding provisions. The assessment framework under the Act contemplated completion of assessment within a limited period, and the maximum period reflected in the scheme was five years. On that basis, revisional power should ordinarily be exercised within three years and in any case not beyond five years. As the impugned notice was issued after about 51/2 years without disclosing reasons, the challenge raised a jurisdictional question and the writ petition was maintainable.

Conclusion: The notice was not sustainable as it was issued beyond a reasonable period, and the High Court was justified in interfering.

Final Conclusion: The appeal failed, and the dismissal left intact the quashing of the revisional notice.

Ratio Decidendi: Where a revisional statute prescribes no express limitation, the power must nevertheless be exercised within a reasonable period determined from the statutory scheme, and an unexplained delay beyond that period renders the action vulnerable to judicial review.

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