Limitation for sales tax revision turns on service date and timely dispatch; non obstante clause controls and order is time-barred.

Limitation for revision under the Andhra Pradesh General Sales Tax Act was reckoned from service of the assessment order on the assessee. Because the record did not show that the revisional order was timely signed, dispatched, and communicated, an adverse inference was drawn that it had been ante-dated. Section 24-A, as a non obstante provision governing revisions and consequential assessments, prevailed over the broader limitation period relied on by the State. The revisional order and the Tribunal's order were therefore treated as barred by limitation and set aside.

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Issues: Whether the revisional order and the Tribunal's order were barred by limitation under the Andhra Pradesh General Sales Tax Act, 1957 and liable to be set aside.

Analysis: The period of limitation was reckoned from the date on which the assessment order was served on the assessee. On the dates stated and the circumstances of service and dispatch, the revisional order did not appear to have been passed and communicated within the prescribed time. In the absence of material showing timely signing and dispatch, an adverse inference was drawn that the order was ante-dated. Section 24-A, being a non obstante provision, governed revisions and consequential assessments and required action within the prescribed period, overriding the broader limitation period relied upon by the State.

Conclusion: The revisional order and the Tribunal's order were barred by limitation and were set aside.

Ratio Decidendi: Where the record does not support timely passing and service of a revisional order, and the applicable limitation provision contains a non obstante clause governing revisions, the authority's order is liable to be treated as time-barred and set aside.

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