https://www.taxtmi.com/caselaws?id=45790 A general revisional power under the Sea Customs Act could not be used to reopen and recover an allegedly erroneous refund after the express three-month limitation for recovery had expired. The specific limitation in the recovery provision governed, and the broader supervisory revision power could not override it without making the statutory time bar ineffective. A writ petition under Article 226 was also maintainable at the notice stage because the proposed recovery was jurisdictionally barred from the outset; a party need not wait for completion of an unlawful proceeding before seeking relief. en-us Wed, 20 Sep 1961 00:00:00 +0530 Tue, 13 Jul 2010 18:02:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=45790 A general revisional power under the Sea Customs Act could not be used to reopen and recover an allegedly erroneous refund after the express three-month limitation for recovery had expired. The specific limitation in the recovery provision governed, and the broader supervisory revision power could not override it without making the statutory time bar ineffective. A writ petition under Article 226 was also maintainable at the notice stage because the proposed recovery was jurisdictionally barred from the outset; a party need not wait for completion of an unlawful proceeding before seeking relief. Case-Laws Customs Wed, 20 Sep 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=45790