https://www.taxtmi.com/caselaws?id=306908 Section 23(4)(a) of the Orissa Sales Tax Act, read with Rule 80 of the Orissa Sales Tax Rules, was construed to require the Commissioner's suo motu revisional proceedings to end in a final order within three years from the date of the order sought to be revised. The provision was read as a whole, so the three-year limit governed not only the initiation of revision by calling for records but also the completion of the revisional order. A contrary interpretation would allow indefinite pendency and defeat the statutory scheme of limitation and finality. The earlier decision on Section 12(7) was distinguished because it dealt only with reopening, not the time for passing the revisional order. en-us Wed, 10 Jul 2019 00:00:00 +0530 Sun, 05 Mar 2023 16:59:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306908 Section 23(4)(a) of the Orissa Sales Tax Act, read with Rule 80 of the Orissa Sales Tax Rules, was construed to require the Commissioner's suo motu revisional proceedings to end in a final order within three years from the date of the order sought to be revised. The provision was read as a whole, so the three-year limit governed not only the initiation of revision by calling for records but also the completion of the revisional order. A contrary interpretation would allow indefinite pendency and defeat the statutory scheme of limitation and finality. The earlier decision on Section 12(7) was distinguished because it dealt only with reopening, not the time for passing the revisional order. Case-Laws VAT and Sales Tax Wed, 10 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306908