Limitation for revisional tax orders: an order passed beyond the statutory period was held void and set aside.

A revisional order under the Andhra Pradesh Value Added Tax Act, 2005 was invalid where it was passed after the statutory limitation period had expired. The court treated the decisive date as the point from which revisional power could lawfully be exercised and found that the impugned order was made well beyond that period. On that basis, the revision was held to be barred by limitation, and the writ petition succeeded with the revisional order and consequential proceedings set aside.

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Issues: Whether the revisional order was barred by limitation under Section 32 of the Andhra Pradesh Value Added Tax Act, 2005.

Analysis: The petitioner's assessment for the relevant years had been subjected to revision after the appellate order. The decisive date for limitation was the date from which the revisional power could validly be exercised, and the record showed that the impugned revisional order was passed much later than the permissible period. On that basis, the order was held to have been made beyond limitation.

Conclusion: The revisional order was barred by limitation and was liable to be set aside.

Final Conclusion: The writ petition succeeded, and the impugned revision order and its consequential proceedings were annulled.

Ratio Decidendi: A revisional order passed after expiry of the statutory limitation period is void and liable to be set aside.

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