Judgment :- Ramaswami, J. The surplus lands as determined under the Tamil Nadu Land Reforms (Fixation of Ceiling on Land) Act, 1961 of the respondent was acquired after publication of a notification to that effect that the surplus lands are required for a public purpose, by the notification published under section 18(1) on 30th October, 1973. Thereafter the Authorised Officer, Coimbatore, within whose Jurisdiction the lands are situate, proceeded to determine the amount of compensation for the lands acquired as provided in Chapter VI of the said Act. It appears that the respondent landowner showed supine indifference and allowed the Authorised Officer to determine whatever amount he may decide as just and reasonable. Therefore, it is even when he was asked to submit his claim he did not make any claim. The Authorised Officer, by his order, dated 8th March, 1975 determined the amount of compensation payable at the rate specified in Schedule III of the Act. He determined the total extent of the surplus lands acquired and with reference to the gross produce and other particulars referred to in the order, fixed the fair rent and the net annual income and ultimately on the basis of those findings also determined the compensation payable as Rs.1,59,950.66. After giving these findings, the order further stated- “I, therefore, order that the sum of Rs.1,59,950.66 (Rs. One lakh fifty-nine thousand nine hundred fifty and paise sixty-six only) has been determined to be paid to minor Ramachandra Krishna-kumar g/m. Tmt. Andalammal, S/o.Krish-nama Naidu, Maniagar Thottam, Palla-modupudur, Coimbatore taluk, towards compensation payable for the above surplus lands acquired under the T.N.L.R. (R.C.L.Act 1970)”. In accordance with this order and as required under section 50(3)(a) and (b) lead with rule 45 of the Tamil Nadu Land Reforms (Fixation of Ceiling on Land) Rules, 1962, the Authorised Officer prepared the draft assessment roll in Form No.22, and a statement referred to in section 50(3)(i) in Form No.23, and issued a notice referred to in section 50(3)(a)(ii) in Form No.24. This draft assessment roll is dated 27th May, 1975 and that was published on 9th July, 1975 in the Gazette. The notice in Form No.24 to the respondent was served on 4th March, 1976. This draft assessment roll is dated 27th May, 1975 and that was published on 9th July, 1975 in the Gazette. The notice in Form No.24 to the respondent was served on 4th March, 1976. Even for this notice the respondent did not file any objection and he was satisfied with the determination of the extent of surplus lands, the classification of the surplus lands as wet and dry, the determination of the gross produce, the fair rent and the annual income as also the final compensation payable, accepting whatever that was determined and that compensation may be paid to him at the earliest. 2. Though the Act did not contemplate any further action to be taken in such circumstances, except to publish the draft assessment roll finally as required by clause (b) of section 50 more than two and a half years after the order, the Authorised Officer seemed to have sent a copy of the draft assessment roll to the Land Commissioner in his reference 198/MR-III/A-1 dated 18th October, 1977. The Land Commissioner called for reports from the Authorised Officer, as to how he determined the gross produce, the fair rent and the annual net income and thereafter sought to verify the same from the Director of Agriculture. This inter-departmental correspondence on this account was going on till 18th January, 1979. On that day, we find from the note file produced before us today that the Officer had put up a note to the Land Commissioner, the various valuations received from various authorities and sought for orders as to whether the draft assessment roll published by the Authorised Officer, Coimbatore, could be accepted and final publication may be ordered. At that stage, the Land Commissioner seems to have entertained a doubt as to the correctness of the determination of the gross produce, the net income and the net compensation and accordingly decided to initiate suo motu proceedings under section 82 and issued a notice dated 18th January, 1979 to the respondent. At that stage, the Land Commissioner seems to have entertained a doubt as to the correctness of the determination of the gross produce, the net income and the net compensation and accordingly decided to initiate suo motu proceedings under section 82 and issued a notice dated 18th January, 1979 to the respondent. In this notice, the Land Commissioner stated that the Authorised Officer in his proceedings dated 8th March, 1975 has fixed the compensation for the lands measuring 44.11 acres of dry in Vilankurichi village and 4.21 acres of dry and 3.92 acres of wet in Pichanur village as if dry lands were cultivated with cholani and wet lands with paddy and that a perusal of the adangal shows that the extent cultivated differed from those mentioned therein. He also pointed out that the Authorised Officer has adopted the yield of cholam at a particular quantity and adopted the price for paddy at a rate higher than that fixed by the Government under the Maximum Prices Order at the time of section 18(1) notification and these irregularities have been committed in the determination of the compensation by the Authorised Officer in his proceedings, dated 3th March, 1975. The notice further stated that under the powers vested under section 82 of the Act, the Land Commissioner proposed to direct the revision of the compensation as stated in the notice. It may be mentioned that in this notice the total compensation was proposed to be determined at Rs.65,082.77. There was an objection to this but final order was made on 11th June, 1979 determining the compensation as stated in the notice, dated 8th March, 1975 and the Authorised Officer was directed to take action afresh in accordance with law. 3. The respondent filed W.P.No.4553 of 1979 praying for the issue of a writ of certiorari to quash the order dated 11th June, 1979. Apart from questioning the jurisdiction of the Authorised Officer, Land P forms, Coimbatore, in sending the papers to the Land Commissioner, asking for approval of the draft roll for final publication, the respondent has questioned the jurisdiction of the Land Commissioner to invoke the jurisdiction under section 82 to revise the order dated 8th March, 1975 on the ground that even-if he had jurisdiction it is barred by limitation. This contention of the respondent that the order of the Authorised Officer, dated 8th March, 1975, should not have been revised by the Land Commmissioner and that it is barred by limitation was accepted by the learned single Judge, who heard the writ petition and the writ petition was allowed and the order of the Land Commissioner was set aside It is against this order the present appeal has been filed. 4. Rule 62(2) of the Tamil Nadu Land Reforms (Fixation of Ceiling on Land) Rules, 1962, prescribes the time-limit for exercising the suo motu power of revision under section 82 of the Act. That provision read as follows: “The power of suo motu revision under section 82 shall be exercised by the Land Commissioner, within a period of three years, from the date of the order, decision or proceedings, referred to in the said section.” This provision was amended by G.O.Ms.No. 912, dated 19th April, 1978 whereby the period of 3 years was changed into five years. According to the learned Counsel for the respondent, what was sought to be revised by the Land Commissioner was the order of the Authorised Officer, Land Reforms, Coimbatore, dated 8th March, 1975. In fact, the notice dated 18th January, 1979 proposing the exercise of powers under section 82 to revise the compensation refers to the order of the Authorised Officer, dated 8th March, 1975 only and it specifically states that in determining the gross produce, the fair rent and the annual income, the Authorised Officer committed irregularities and that is the thing which they wanted to set right in the exercise of the suo motu power. The final order dated 11th June, 1979 also refers to the irregularities in the order, dated 8th March, 19/5 in fixing the compensation and sets out the various irregularities therein and ultimately set aside the order and directed the preparation of a fresh draft assessment roll in accordance with the findings therein and in accordance with law. The order was sought to be revised and under the suo motu proceedings taken under section 82 in the order fixing compensation, dated 8th March, 1975. If so, the three year period as it was originally provided for under rule 62(2) had expired on 8th March, 1978. The order was sought to be revised and under the suo motu proceedings taken under section 82 in the order fixing compensation, dated 8th March, 1975. If so, the three year period as it was originally provided for under rule 62(2) had expired on 8th March, 1978. The amendment in G.O.Ms.No.912, Revenue, dated 19th April, 1978 extending the period from three years to five years could not have been relied on as by that j time, the three year period was over and j the limitation could not have been saved. In fact section 112 specifically states that all rules made under this Act shall be published in the Fort St. George Gazette and unless they are expressed to come into force on a particular day, shall come into force on the day on which they are published. We do not know as to when the G.O.Ms.No.912 was published but even taking the date 9tn April, 1978 as relevant, the amended rule was prospective in operation and would not revive the order which had already become final. The proceedings initiated, therefore, would be clearly barred by limitation. 5. However, it was contended by the Government Pleader for the appellants that the date relevant for the purpose of finding out the limitation for suo motu revision is the date on which the draft assessment roll was published, namely 9th July, 1975 and if that date is taken, the amendment extending the period of limitation to five years being made even before the end or three years, the exercise of suo motu power is well within the period of limitation prescribed under rule 62(2) and further, since the amendment related to limitation which is procedural it would apply to all orders which had not become final even though the order was made prior to the amendment coming into force. The learned Government Pleader may be right in his contention that the amended rule will apply to all these orders which had not become final, barred under the rule then existing. However, we are unable to agree with the learned Government Pleader that what was sought to be revised was the draft assessment roll which was published on 9th July, 1975 and that the period of limitation was not over. The relevant provision in section 50(3) reads as follows: “(3)(a). However, we are unable to agree with the learned Government Pleader that what was sought to be revised was the draft assessment roll which was published on 9th July, 1975 and that the period of limitation was not over. The relevant provision in section 50(3) reads as follows: “(3)(a). The Authorised Officer shall determine the amount at the rate specified in Schedule HI, and prepare a draft assessment roll in such manner and containing such particulars as may be prescribed. He shall cause it to be published together with- (i) a statement that the amount specified therein is the entire amount payable for all interests in the land and that subject to the other provisions of this Act, the persons named therein are the only persons who are entitled thereto in the proportion stated therein, and (ii) a notice stating that objections, if any, . in respect of any entry in the draft may be preferred by any person in such manner as may be prescribed within thirty days from the date of the publication. (b) The Authorised Officer shall cause to be served on the persons whose names appear in the draft aforesaid a copy of the draft together with a copy of the said statement and of the notice.” Rule 45 is the rule which prescribes the manner in which the publication of the draft assessment roll has to be made and that rule reads as follows: “Draft assessment roll - The draft assessment roll referred to in section 50(3)(a) shall be prepared in Form 22. The Authorised Officer shall also record in a separate order his reasons for arriving at the findings set out in the draft assessment roll. (c) The statement referred to in section 50(3)(a)(i) and the notice referred to in section 50(3)(a)(ii) shall be in Forms 23 and 24 respectively. (3) The draft assessment rolls referred to in sub-rule (1) together with the statement and the notice referred to in sub-rule (2) shall be published in the manner specified in rule 12(2).” It may be seen from the first part of the first sentence in section 50(3)(a), the Authorised Officer is required to-determine the amount of compensation payable at the rate specified in Schedule III and this is a separate order and does not form part of the draft assessment roll as such. It is also clear from Rule 45 extracted above which required the Authorised Officer to record in a separate order his reasons for arriving at the findings set out in the draft assessment roll. It is made when the draft assessment roll is required to be made in accordance with the order made by him and the figures and the other particulars are filled up with reference to his order but there is no doubt that it is a separate order and is to be different. The reason for determining the gross produce, the annual net income and the fair rent and fixing the compensation are all to be set out separately and do not form part of the draft assessment roll. In fact the original notice of 18th January, 1979 as also the final order referred to the irregularities in the order dated 8th March, 1975 only and there was no irregularity in the final assessment roll. For the purpose of finding out what is the order sought to be revised there can be no doubt that it is the order dated 8th March, 1975 that is sought to be revised and when that order is revised automatically the various other findings will have to be revised, the entries in the draft assessment roll also will have to be revised, but those things make no difference in the consideration as to what was the order sought to be revised. We have no doubt that the order sought to be revised is the order dated 8th March, 1975 and there is no question of revising the draft assessment roll. That is only the substantial order made in pursuance of the revision. It may also be seen from rule 45 that the draft assessment roll which is to be in Form No.22 does not make the order itself as a part of it, whereas the statement referred to in section 50(3)(a)(1) is to be specifically enclosed and the notice also should be in accordance with Form No.24 as required in section 50(3) (a)(ii). We have therefore no doubt that the order that was revised and which could have been revised under section 82 is the order dated 8th July, 1975 and not the draft assessment roll said to have been published on 9th July, 1975. We have therefore no doubt that the order that was revised and which could have been revised under section 82 is the order dated 8th July, 1975 and not the draft assessment roll said to have been published on 9th July, 1975. If that is so, the order became final on 8th March, 1978 as per rule 62 before its amendment and the amendment of the rule extending the period would not affect that position and could not confer any jurisdiction on the Land Commissioner to revise that order. 6. It was then contended by the learned Government Pleader that the process of revising the order in exercise of the powers under section 82 had began even when the draft assessment roll was received by the Land Commissioner from the Authorised Officer on 18th October, 1977 and when he called for the report from the Authorised Officer as to how he determined the gross produce, fair rent and annual rent and that was long before the period of three years expired and that, therefore, the amended provision will apply. In this connection, he also relied on the decision of the Full Bench in Gulam, Mohidoen v. Commissioner of Agricultural Income-tax, Board of Revenue, Madras, 1978)2 L.T.J.29= (1978) Tax.L.R.895= I.L.R. (1978)3 Mad.23= 113 I.T.R.837= (1978) 91 L.W.307= A.I.R.1978 Mad.327. We are clearly at a loss to understand how the Land Commissioner seeking to verify the correctness of the determination of the gross produce, fair rent and annual rent would in any way amount to a decision, Surely, if the Land Commissioner has found the determination to be correct, he would not have issued any notice. It is only when he found actually that there were any irregularities, that he proposed to take action and that decision to invoke section 82 of the Act was made, as already stated, only on 18.1.1979. Taking a decision to revise the order suo motu cannot be done arbitrarily. If it is said that the revision process had been initiated on 18th October, 1977 itself, that was without any material and at that stage he could not have entertained any doubt as to the irregularities or incorrectness of the figures. It appears to be a routine correspondence for verification of the order. If it is said that the revision process had been initiated on 18th October, 1977 itself, that was without any material and at that stage he could not have entertained any doubt as to the irregularities or incorrectness of the figures. It appears to be a routine correspondence for verification of the order. Not only there is nothing on record to show that he had specifically invoked the power under section 82 at that stage itself, but there is also a definite note in the office file on 18th January, 1979 bringing to the notice of the Land Commissioner the various figures produced by the various authorities on the prices of various commodities produced, the extent of land cultivated and the fair rent normally obtainable and seeking orders of the Commissioner and it is only at that stage the Land Commissioner also decided that there were some irregularities in the order and accordingly directed issue of notice to the respondent to show cause why the order dated 8.3.1975 should not be revised. In the circumstances, therefore, we are unable to agree with the learned Government Pleader that the process of revision started even much earlier than 18. 1.1979. 7. The decision in Gulam Mohideen v. Commissioner of Agricultural Income-tax. (1978)2 I.T.J.29= 91 L.W.307 relied on also has no relevance and it does not also support the case of the Government Pleader. That was a case arising under the provisions of the Madras Agricultural Income-tax Act, 1955. The assessee invoked the powers of revision of the Commissioner by filing a revision petition before him under section 34 of the Act. The revision petition was however returned by the Commissioner with an endorsement that there was no time for him to pass the order within the period of three years prescribed under section 34(2)(c) and that therefore he was obliged to return the revision petition. It may be mentioned that the order sought to be revised was dated September 30.9.1971 and the petition was filed on 24th September, 1974. It may be mentioned that the order sought to be revised was dated September 30.9.1971 and the petition was filed on 24th September, 1974. The petitioner’s contention was that once an application for revision Is filed under section 34 within three years from the date of the order sought to be revised, the revisional authority has to entertain the revision petition and deal with it on merits, that the view taken by the Commissioner that final orders in the revision petition could not be passed within three years is erroneous and that the said section merely prescribed the time limit for invoking the revisional jurisdiction and not for passing final orders in the revision petition. Section 34 the scope of which was considered in that case read as follows: “The Commissioner may, of his own motion or an application by an assessee, call for the records of any proceeding under this Act, which has been taken by any authority subordinate to him and may make such enquiry or cause such enquiry to be made and, subject to the provisions of this Act may pass such orders thereon as he thinks fit.” Sub-section (2) of that section provided that an order shall not be revised by the Commissioner under this section where the order has been made more than three years previously. Though revision petition was filed by the assessee invoking the powers of the Commissioner under section 34, within the period of three years, merely on the ground that a consideration of it and making of a final order after issuing notice to the parties was not possible to be made before three years the application was returned. The contention of the petitioner was accepted by the learned judges. The passage relied on by the learned Government Pleader in this judgment is as follows: “Further, the word ‘revise’ in- section 34(2) is a comprehensive expression and it does not merely denote the passing of the order in revision. The word ‘revise’ cannot be understood to mean pass an order ‘in revision’. Revision is a legal process and does not denote the final act of passing an order terminating the legal process.. The word ‘revise’ cannot be understood to mean pass an order ‘in revision’. Revision is a legal process and does not denote the final act of passing an order terminating the legal process.. The legal process consists of various steps such as calling for the records of the proceedings, making an enquiry by the revisional authority or causing an enquiry to be made thereon, and passing final orders thereon as the revisional authority thinks fit. Therefore, the entire process commencing from the calling of the records and ending with the passing of the final order has been termed as revision in the said section. Each one of the steps in the process is a revisional process. Therefore, if any one of the steps in the process has been initiated within the period of limitation there is no further limitation on the exercise of the power. Therefore, if the assessee has invoked the revisional power within the period of three years as provided for in section 34(l)(c) or if the revisional authority has exercised his suo motu revisional power by calling for the records of the proceedings within the said period, final orders in the revision can be passed at any time thereafter.” We do not agree with the learned Government Pleader that this decision or the passage stated above will in any way support the case of the appellant. There was no calling for the proceedings in exercise of the revisional powers at any stage earlier than the issue of notice under section 82. The inter-departmental correspondence for verification of the Correctness of the figures before a decision to invoke the provisions of section 82, by no stretch of imagination could be considered as calling for the records of the proceedings for satisfying himself as to the correctness of the order sought to be revised. The decision relied on related actually to an application filed by an assessee seeking the jurisdiction of the Commissioner to revise and not one relating to suo motu exercise of revisional powers. In the case of an assessee invoking revisional powers, certainly the calling for the records of the proceedings arises only after entertaining the revision. The decision relied on related actually to an application filed by an assessee seeking the jurisdiction of the Commissioner to revise and not one relating to suo motu exercise of revisional powers. In the case of an assessee invoking revisional powers, certainly the calling for the records of the proceedings arises only after entertaining the revision. The calling for the records within the meaning of this provision would arise only when the Land Commissioner entertained a doubt as to the correctness of the order and decided to invoke the provisions of section 82 to verify and correct the order. It is impossible to agree with the learned Government Pleader that at any time prior to the issue of a notice under section 82 to the respondent, it could be said that there was any process involving section 82. We are of the view that even in the case of unvoking suo motu powers, the proceedings can be said to have been initiated only when the notice under section 82 was issued to the respondent and not earlier. It is all the more so because the notice is issued when there is a doubt and if the respondent is able to show that the determination by the Authorised Officer was correct, the proceedings can be dropped. The initiation of a suo motu proceedings can be said to arise only from the issue of a notice as in the case of an assessee filing a revision with the filing of the revision. Otherwise, it will also be impracticable and impossible to apply the limitation provision. We have no doubt, therefore, that even in the case of a suo motu proceeding the revisional powers could be said to have been invoked only with the issue of a notice to the respondent and it is at that stage the Commissioner also calls for the records of the Authorised Officer officially for the purpose of proceeding under section 82. In the circumstances, therefore, we are unable to agree with the learned Government Pleader that the period of limitation was not over before the proceeedings under section 82 were invoked. 8. In the circumstances, therefore, we are unable to agree with the learned Government Pleader that the period of limitation was not over before the proceeedings under section 82 were invoked. 8. Since even on the assumption that the order dated 8th March, 1975 is one of the orders that could have been revised, the proceeding itself is barred by limitation, it is not necessary for us to consider the other submissions of the learned Counsel for the respondent that the orders under section 50(3) (a) first part, or any proceedings under section 50(3)(a) are not revisable under section 82. 9. For the foregoing reasons, this writ appeal fails and it is dismissed with costs. Counsel’s fee 10. The matter has been pending since 1975. Any further delay will certainly cause great loss and prejudice to the respondent. Accordingly, we direct the Authorised Officer, Land Reforms, Coimba-tore to publish the final draft assessment roll under section 50(5) within a period of one month from this date.