1996 (6) TMI 331

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....rises for consideration in this tax revision case, filed by the assessee, under section 22 of the Andhra Pradesh General Sales Tax Act, 1957, is whether the order of revision passed by the Deputy Commissioner on March 26, 1984 is beyond the period of limitation having regard to the provisions of section 20(3) of the Act. The initial order of assessment was passed on October 19, 1979 which was ser....

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....d be barred by limitation. We are afraid we cannot accede to the contention of the learned counsel for the petitioner. The purpose of section 20(3) of the Act in prescribing the limitation of four years is for exercising the revisionary jurisdiction which has been interpreted to mean initiation of the proceedings and passing a final order by the revising authority. In this view of the matter, the ....