TMI Blog1955 (7) TMI 22X X X X Extracts X X X X X X X X Extracts X X X X ..... g the said revision application on the ground of limitation. The revision application filed before the Collector of Sales Tax was dated the 26th July, 1954, the order which the applicants sought to get revised by him dated the 29th January, 1954. Before making the order the Collector asked the applicants why the application should not be rejected as time-barred, and he found that the reply given, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... opinion, the endorsement of the Additional Collector of Sales Tax below a letter written by him to the Revenue Collector dated 13th August, 1954, in which the applicants were required to pay Rs. 400 "for admission of the revision" had no reference to the question of limitation at all. Shri Shroff has also relied on a decision of the Bombay High Court, Champalal Asharam v. Commissioner of Income-ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that conclusion the said officer issued a notice for the hearing of the appeal. (1) [1953] 23 I.T.R. 464. Even on the supposition that the delay had been condoned, their Lord- ships observed as follows: "But it is open to the Appellate Assistant Commissioner, having taken the view at the intermediate stage under section 30(2) that delay should be condoned, and having admitted the appeal, to revis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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