Mandatory limitation for revision under tax law cannot be extended by general limitation principles once the statutory period expires.

A revisional power under section 263 had to be exercised within two years from the assessment order, and that mandatory period was applied strictly. The attempt to invoke the Limitation Act to extend time was rejected because the special fiscal limitation regime controlled and no material showed that the relevant dates were holidays. Once the statutory period expired, the Commissioner could not validly revise the assessment. The revision was therefore time-barred, without jurisdiction, and void ab initio.

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Issues: Whether the Commissioner's revisionary order under section 263 was barred by limitation and, if so, whether it was without jurisdiction.

Analysis: The applicable provision required the revisional power to be exercised within two years from the date of the assessment order. The assessment order was passed on 12 March 1976, so the revisional authority had to act before expiry of the two-year period. The attempt to extend time by reliance on the Limitation Act was rejected, as the limitation in the special statute had to be applied strictly and no material established that the relevant dates were holidays so as to extend the period. Once the statutory period expired, the revisional power could not be validly exercised.

Conclusion: The revision under section 263 was time-barred, without jurisdiction, and void ab initio; the assessee succeeded.

Ratio Decidendi: Where a special fiscal statute prescribes a mandatory period for exercise of revisional power, that period must be strictly followed and cannot be enlarged by general limitation principles unless the statute itself so permits.

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