ORDER R.S. Shukla Aggrieved by the assessment of certain taxes by the Municipal Committee, Chhindwara, the applicant filed an appeal before the Sub-Divisional Officer (Shri Saxena). Against the order of this Sub-Divisional Officer dated 13-5-1955 an appeal was filed before the Deputy Commissioner, who, by his order dated 29th August 1955 directed Shri K. L. Vaishya, another Sub-Divisional Officer, to review the order of Shri Saxena. The review application was disposed of by Shri Vaishya on 2-1-57 against which the present revision application has been filed under section 58 of the C. P. Municipalities Act (hereinafter called the Act) on 6-4-57. A question arose whether the applicant, in the instant case, can move this Board under section 58 ibid. This being a case of assessment of a tax under the Act, an appeal lies under section 83(1) to the Collector or some other prescribed, officer, and a revision against the appellate order lies to the Board of Revenue under section 83 (1-A). The limitation for revision under section 83 (1-A) is 30 days. Apart from other difference, the Act itself prescribes no limitation for a revision under section 58, although under the rules framed by the Board of Revenue, a party interested to appear must apply within 90 days. The difference of limitation being vital, it is not uneaten that revision applications that would be time-barred under section 83(1-A) are sought to be moved under section 58, as revisional powers of the State Government under both the sections have been delegated to the Board of Revenue. To answer the issue before us, therefore, we have to examine the scope of a revision under the two sections, namely, section 83(1-A) and section 58 of the Act. In other words, we have to determine in what cases the revisional powers of the Board are exercisable under the one or the other section. Incidentally, it may be observed that although section 58 is side-headed as "control of the Provincial Government", the language is in terms with that used for the exercise of revisional powers by the superior officers under section 46 of the M. P. Land Revenue Code or under section 159 of the Local Government Act. There can, therefore, be little doubt that powers delegated to the Board of Revenue under section 58 are revisional powers similar in their nature and scope as those under the analogous Acts cited above. There can, therefore, be little doubt that powers delegated to the Board of Revenue under section 58 are revisional powers similar in their nature and scope as those under the analogous Acts cited above. A comparative reading of the two sections would show that section 58 is, more or less, a general provision and is wider in its scope. Sections 83 (1), 83 (1-A) and 84 ibid, on the other hand, appear under the head "Appeals relating to and the refund of taxes" and are specially intended to provide for appeals and revisions arising out of "the assessment or levy of, or refusal to refund, any tax under the Act". Both in case of an appeal and a revision the limitation prescribed is 30 days while the powers under section 58, as worded, can be exercised at any time. It is a well-known rule of interpretation that "where a general intention is expressed, and also a particular intention which is incompatible with the general one, the particular intention is considered as exception to the general one" (Maxwell, 10th Edition, 172). Thus the general provisions under section 58 must give place to the special provisions of sections 83 to 84, ibid whenever we are concerned in revision with a matter arising out of the assessment or levy of, or refusal to refund a tax. In this view it is clear that the applicant is not entitled to move this Board under section 58. His remedy was to come up in revision within 30 days of the appellate order as per provisions of section 83 (1-A). This he has not done and, even counting from Shri Vaishya's order dated 2-1-57, the present application is late by about 60 days. As a matter of fact, limitation against the applicant should run from 13-3-55, the date of the order of the previous Sub-Divisional Officer (Shri Saxena). This would be so because the order passed later in review by the successor Sub-Divisional Officer, Shri Vaishya, was a legal nullity and can have no force in law. He had no powers of review either with, or without the sanction of the Deputy Commissioner. Powers of review under section 58-B of the Act are exercisable only by the Commissioner or the Deputy Commissioner as the case may be. He had no powers of review either with, or without the sanction of the Deputy Commissioner. Powers of review under section 58-B of the Act are exercisable only by the Commissioner or the Deputy Commissioner as the case may be. The mere fact that appellate powers under section 83 (1) are also exercisable by the Deputy Commissioner does not confer the legal status of the Deputy Commissioner within the meaning of section 58-B, on a Sub-Divisional Officer-who happens to be an officer specially empowered to hear appeals under section 83 (1). Thus the only valid appellate order was that of Shri Saxena dated 13-3-55 and the present petition is, therefore, hopelessly time-barred. The time spent by the applicant in prosecuting his appeal before the Deputy Commissioner cannot be deducted in his favour under section 14 of the Limitation Act, as that provision comes into play only when a matter is prosecuted bona fide in a wrong Court which is unable to entertain it for lack of powers and is dismissed accordingly. The law is very clear on the point. No appeal lay to the Deputy Commissioner nor a review was permissible. If the applicant wasted time in wrong Courts, in spite of very clear provisions of law, he would not be protected by section 14 of the Limitation Act. The position that emerges is that the order of the Sub-Divisional Officer, Shri Saxena, having been validly passed, shall stand. It cannot be interfered with in this revision, as, to do so would be precluded by the bar of limitation. The subsequent order of the Sub-Divisional Officer Shri Vaishya, being a legal nullity, would stand quashed. Revision application is disposed of accordingly. Application allowed.