JUDGMENT - (1) This petition raises a very short question as to the interpretation of the period of limitation provided under section 33A for the making of an application by the assessee for revision.

(2) The appellate Assistant Commissioner made the order on the 9th January 1956. The order was served upon the assessee on the 27th January 1956, and the assessee made the application for revision under section 33A on the 25th January 1957. the period of limitation is one year form the date of the order or within such further period as the Commissioner may think fit to allow on being satisfied that the assessee was prevented by sufficient cause from making the application within that period, and the contention of the Department is that limitation begins to run from the date of the order viz., the 9th January 1956, and in as much as the application was made on the 25th January 1957 the application is out of time. On the other hand, the contention of the assessee is that limitation begins to run from the date when the assessee came to know of the order, which is the 27th January 1956, and therefore his application is within time.

(3) Mr. Joshi has drawn our attention to various sections i

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