Statutory limitation in tax revision renders an order invalid when passed after the prescribed period has expired.

A revisional order passed under the Andhra Pradesh Value Added Tax Act, 2005 after expiry of the prescribed limitation period is invalid. On the facts stated, the revisional order was made beyond the permissible time limit measured from the order under revision, so it was held to be barred by limitation and liable to be set aside.

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

Analysis: The revisional order was passed on 21.04.2022, whereas the order under revision had been passed on 09.02.2018. On the facts noted, the period prescribed for revision had expired before the revisional order was made. The challenge was therefore accepted on the ground that the revision was initiated and concluded beyond the permissible time limit.

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

Ratio Decidendi: A revisional order passed after expiry of the statutory limitation period is invalid and cannot be sustained.

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