Limitation for suo motu revision under VAT law runs from initiation of revisional proceedings, not earlier refund verification steps.

The one-year limitation for suo motu revision under Section 63-A(3) of the Karnataka Value Added Tax Act ran from the initiation of revisional proceedings, not from an earlier endorsement that only sought verification of a refund claim and records. Because the revisional notice was issued on 10.07.2014 and the final order followed on 21.02.2015, the order was within time. The prior view that the revision was time-barred failed to account for this distinction, and the jurisdiction challenge on limitation grounds was unsustainable.

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Issues: Whether the revisional order under Section 63-A(3) of the Karnataka Value Added Tax Act, 2003 was barred by limitation and without jurisdiction.

Analysis: The appeal turned on the starting point for the one-year period prescribed for suo motu revision. The prior endorsement dated 11.03.2013 concerned verification of the refund claim and calling for records in that context, whereas the revisional proceedings under Section 63-A were initiated only upon the notice dated 10.07.2014. On that basis, the final revisional order dated 21.02.2015 fell within one year of initiation. The earlier order setting aside the revision on limitation grounds did not consider these material facts.

Conclusion: The limitation objection was unsustainable, and the revisional order was not shown to be beyond jurisdiction on that ground.

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