Judgment :- In this writ petition, the petitioner challenges the levy of tax under the Kerala Building Tax Act, 1975 (hereinafter referred to as 'the act) and the consequent recovery proceedings. The building in respect of which the assessment is made belongs to a private limited company, known as 'M/s. Hotel Kandath International Pvt. Ltd'., which is stated to be a' three star hotel'. The petitioner is the Managing Director of the Company. He claims that as per the Notification of the Government dated 11-7-1986 the Department of Tourism is authorised to grant exemption from payment of tax in respect of the buildings" coming within the category of 'three star hotel'. 2. Ext. P1 is the order of assessment dated 31-10-1980. Ext. P2 is the demand notice calling upon the petitioner to pay a sum of Rs. 2,49,222/- towards building tax. Exts. P7 and P8 are the demand notices issued under the provisions of the Kerala Revenue Recovery Act seeking to recover the amount demanded towards building tax. By Ext. P3 the petitioner requested the Tahsildar that the above building may be exempted from payment of building tax in view of the aforesaid notification. In reply the Tahsildar sent Ext. P4 dated 23-12-1988 stating that the assessment has already been made and therefore he cannot interfere in the order issued by him. Thereupon the petitioner submitted. Ext. P5 petition dated 25-1-1989 before the District Collector requesting to revise suo mote, the order passed by the Tahsildar., under S.13 of the Act. That petition was rejected by Ext. P6 order dated 1-2-1989 mainly on the ground that it was not filed within thirty days as provided in sub-section (3) of S.13 of the Act. That order passed by the District Collector is under challenge. 3. The main question that calls for determination in this case is whether the petitioner is entitled to invoke power of suo mote revision conferred on the District Collector under S.13 of the Act. S.13 of the Act as stood at the relevant time reads thus: 13. Power of revision of the District Collector. 3. The main question that calls for determination in this case is whether the petitioner is entitled to invoke power of suo mote revision conferred on the District Collector under S.13 of the Act. S.13 of the Act as stood at the relevant time reads thus: 13. Power of revision of the District Collector. (1) The District Collector may, either suo mote or on application by any person aggrieved, call for and examine the record of any order passed by the appellate authority or the assessing authority and may pass such order in reference thereto as he thinks fit: Provided that no such order shall be passed under this sub-section without notice to the party who may be affected by the order. Provided further that the District Collector shall not call for and examine the record of any order passed by the assessing authority. (a) iflhepcriodofthirtydaysspccifiedforpresentationofappealundersub-section(3) of S.11 has not expired; or (b) if an appeal against that order is pending before the appellate authority*; Provided also that no order passed on the basis of a reference under S.12 to the extent covered by the answer to such reference shall be subject to revision by the District Collector. (2) The District Collector shall not suo mote revise an order under sub-section (1) if that order has been passed more than three months previously. (3) An application under sub-section (1) by an aggrieved party shall be made before the expiry of thirty days from the dale on which the order in question was communicated to him. Under the above provision, the power of revision can be exercised by the District Collector either 'suo mote' or 'on application' by the aggrieved party. The District Collector is authorised under this provision to call for and examine the record of any order passed by the lower authorities and make such order as he thinks fit. The power of revision suo mole shall not be exercised by the District Collector if the order sought to be revised has been passed more than three months previously as provided in subsection (2). In other words, the suo mote revision shall not be exercised by the District Collector after the expiry of three months from the date of the order sought to be revised. In other words, the suo mote revision shall not be exercised by the District Collector after the expiry of three months from the date of the order sought to be revised. In the case of revision'on application', it shall be presented within thirty days from the date on which the order in question was communicated to the party as provided in subsection (3). 4. In the present case the Ext. P5 petition is filed by the petitioner specifically seeking to invoke the suo mote revisional power of the District Collector under S.13(1) of the Act. The question is whether such a petition is maintainable. Can an aggrieved party, without moving for revision'on application', seek interference of the District Collector suo mote? It is an admitted case that the petitioner has filed the present petition after the expiry of thirty days. 5. A similar question arose for consideration before this court in Balackandran v. SafctaJt order (1987) (2) KLT 118 = (1987) 67 STC 218). There toe question was whether an assessee under the Kerala General Sales tax Act could invoke suo mote power of revision under S.35 of toe Kerala General Sales tax Act notwithstanding toe specific power conferred on him under S.36 for revision before the Deputy Commissioner. Under S.35 toe Deputy Commissioner has power of revision suo motu within a period of four years from toe date of toe order, whereas under S.36 the Deputy Commissioner has power of revision on application by any person objecting to an order within a period of thirty days from toe date on which a copy of toe order was served. After analysing the provisions and case law on the subject, T.L. Viswanatoa Iyer, J. held: "It is therefore clear that an assessee is entitled to invoke the suo mote power of revision of the Deputy Commissioner under S.35. It is open to the assessee to bring to the notice of the Deputy Commissioner any error, illegality or impropriety in-any order or proceeding of a subordinate officer or authority. The Deputy Commissioner functioning under S.35 is bound to exercise the power keeping in mind the purpose for which it is conferred, namely, to ensure that injustice is avoided". An against toe above decision, toe Revenue has filed a writ appeal. The Deputy Commissioner functioning under S.35 is bound to exercise the power keeping in mind the purpose for which it is conferred, namely, to ensure that injustice is avoided". An against toe above decision, toe Revenue has filed a writ appeal. The Division Bench while concurring with toe above decision observed in Dy Commissioner v. Balachandran (1988) (1) KLT 233) that toe purpose for which toe power of revision is couched in very wide term s is only to safeguard the interest of Revenue and also that -f of the assessee. The Division Bench also observed: "It is true that the language of S.35 literally states that the power has to be exercised suo motile When circumstances warranting the exercise of the power comes to the notice of the concerned authority, the mere fact that the circumstances for the exercise of that power are shown to exist, by the assessee in a particular case, cannot be a factor or reason for the non-exercise or refusal to exercise the said power". (Italics supplied) 6. The question to be considered is -whether toe interpretation given as per toe aforesaid decisions in so far as toe provisions contained in Ss.35 and 36 of the Kerala General Sales tax Act can straightaway be made applicable to the provisions of S.13 of to the Act. In case such interpretation is given to S.13 it will not be in consonance with toe literal meaning of the provision. The revisional power given 10 toe District Collector V under S.13 is to "call for an examine the record of any order passed by the appellate authority or the assessing authority and may pass such an order in reference thereto as he thinks fit". In case toe interpretation, so 'pointed out above, is. given it will result in adding one more mode of exercise of power, namely, exercise of suo mote power of the District Collector at the instance of toe aggrieved party. This will be in addition to two modes of exercise of revisional power as plainly stated in S.13. Any addition or subtraction to the literal, ordinary and plain meaning of the. provision cannot be countenanced.' 7. Now let us examine the position under S.36 of the Kerala General Sales tax Act. The remedy available under that section can be invoked both by the assessee and the revenue as interpreted by the decisions referred to herein before. Any addition or subtraction to the literal, ordinary and plain meaning of the. provision cannot be countenanced.' 7. Now let us examine the position under S.36 of the Kerala General Sales tax Act. The remedy available under that section can be invoked both by the assessee and the revenue as interpreted by the decisions referred to herein before. In this context the following observation of the learned single judge is very relevant: 'The fact that the order or proceeding sought to be revised is appealable or that the assessee has not invoked the power of revision under S.36 is not relevant in this context". This is so because the revisional powers under Ss.35 and 36 of the Kerala General Sales tax Act are different and distinct and one cannot preclude the other. In the case of S.13 of the Act, revisional power is one and the same but only two modes of exercise of that power are prescribed. 8. It is pointed out that the provisions contained in S.13 of the Act are analogous to the provisions contained in Ss.35 and 36 of the Kerala General Sales tax Act. Therefore, the argument is that the principles contained in the decisions in (1987 (2) KLT 118) and (1988)(1) KLT 233) can be applied while interpreting the provisions of S.13 of the Act by analogy. The Supreme Court repeatedly warned against the interpretation of the provisions of law by analogy. In the construction of statutory provisions reasons founded upon analogies are hardly applicable. The provisions of law have to be interpreted as it existed in the statute and the language of one of the provisions of law ..cannot be imported into another. The Supreme Court in Hari Kheu Gawali v. Deputy Commissioner of Police (AIR 1956 SC 559) observed thus: "Arguments by analogy may be misleading. It is not safe to pronounce on the provisions of one Act with reference to decisions dealing with other Acts which may not be in pari materia". Therefore, it is difficult for this court to interpret S.13 of the Act applying the ratio of the decisions aforesaid, though some of its words and phrases have similarity or resemblances to those used in S.35 of the Kerala General Sales tax Act. 9. Therefore, it is difficult for this court to interpret S.13 of the Act applying the ratio of the decisions aforesaid, though some of its words and phrases have similarity or resemblances to those used in S.35 of the Kerala General Sales tax Act. 9. The creation of another mode of exercise of power under S.13 of the Act by interpreting it as suggested by the petitioner would result in anomalous situations. In case an aggrieved party has moved an application for revision under S.13 and obtained an adverse order, he can still move tine District Collector by filing another petition for invoking same power 'suo motu'. An aggrieved party who failed to move the District Collector for exercising his revisional power 'on application' within the period prescribed in that behalf, can move for exercise of power' suo motu' even after the expiry of that period and within the period prescribed for exercising power 'suo motu'. Therefore' the interpretation of a provision of law should not pave the way for the parties to have chances of its misuse or improper application. 10. Sub-section (4) of S.13, which is added as per the Kerala Building Tax (Amendment) Act, 1992 prescribes that "No application for revision under sub-section (1) by an aggrieved party shall lie unless fifty per cent of the building tax Mas been paid". If this court interprets that suo mote power of the District Collector can also be invoked by an aggrieved party, he can seek relief under S.13 without paying 50% of the tax as provided in sub-section (4). That means, very purpose of the provision itself can be defeated. The function of the court while interpreting a provision of law is not to supplant the purpose but to supplement true meaning to it. 11. A new mode of exercise of specific power under a statute which is not otherwise available on a plain reading of a provision cannot be created by interpretation. It will be against the intention of the legislature. The general principle is that the court can neither extend the statute to a case not within its terms nor curtail it by leaving out a case that the statute literally includes. It will be against the intention of the legislature. The general principle is that the court can neither extend the statute to a case not within its terms nor curtail it by leaving out a case that the statute literally includes. Lord Diplock in Dupport Steels Ltd v. Sire (1980) 1 WLR 143) observed: "Where the meaning of the statutory words is plain and unambiguous it is not for the judges to invent fancied ambiguities as an excuse for failing to give effect to its plain meaning because they themselves consider that the consequences of doing so would be inexpedient, or even unjust or immoral Under our constitution it is Parliament's opinion on these matters that is paramount. But if this be the case it is for Parliament, not for the judiciary, to decide whether any changes should be made to the law as stated in the Acts, ". Lord Simon of Gltisdzlein Stock v. Frank Jones (Tipton) Ltd. (1978 (1) All.E.R.948) explained 'Lord Wensleydale's golden rule' of statutory construction (Caledonian Railway Co. v. North British Railway Co. (1881) App.Cases 114) as below: "counsel for the appellants was founding himself on the rider in what has become to be known as "Lord Wensleydale's golden rule of statutory construction, namely one is to apply statutory words and phrases according to their natural and ordinary meaning without addition or subtraction, unless that meaning produces injustice, absurdity, anomaly or contradiction, in which case one may modify the natural and ordinary meaning so as to obviate such injustice etc. but no further". (Italics supplied) In Keshavananda Bharathi v. State of Kerala (AIR 1973 SC 1461) the Supreme Court observed "where the language of an Act is clear and explicit effect is to be given to it whatever may be the consequences. The words of the statute speak the intention of the Legislature". See what the old maxim reminds us: "Absoluta sententia expositore non eget", namely, the plain words need no explanation'. The language contained in S.13 of the Act is plain, unequivocal and unambiguous and it docs not require an interpreter at all. 12. It cannot at any rate be said that the petitioner is not entitled to invoke the revisional power of the District Collector under S,13 of the Act as against the order of the assessing authority. The language contained in S.13 of the Act is plain, unequivocal and unambiguous and it docs not require an interpreter at all. 12. It cannot at any rate be said that the petitioner is not entitled to invoke the revisional power of the District Collector under S,13 of the Act as against the order of the assessing authority. This is not a case where the petitioner has earlier moved the District Collector 'on application' and obtained an adverse order. If he has done so he is precluded from moving again under whatever form or method it may appear to be. In fact the period for invoking the revisional remedy'on application' has been expired and probably that may be the reason for invoking the 'suo motu' revisional power. Either 'on application' or 'suo motu' the revisional remedy available under S.13 cannot be denied to an aggrieved party. In the present case petitioner has received Ext. P1 order on 7-12-1988 and he sent representation on 17-12-1988. He has received reply on 10-1-1989 from the assessing authority refusing to interfere. On 25-1-1989 the petitioner has filed Ext. P5 petition before the District Collector. If it is treated as one invoking the revisional remedy'on application', there is a delay of 19 days. In fact the District Collector had treated Ext. P5 as an application for exercise of revisional power by an aggrieved party, but it was rejected on the ground of limitation. It is definite from the facts set out in the petition that the petitioner was diligent all along in pursuing his remedies and the explanation offered for delay appears to be sound. The petitioner shall not therefore be denied the revisional remedy under S 13 of the Act. In exercise of my discretionary power under this extra-ordinary jurisdiction, I accept the explanation offered for delay in filing revision by the petitioner and treat Ext. P5 as one for invoking the revisional power of the District Collector 'on application' under S.13 of the Act. In that view of the matter I set aside Ext. P6 order of the Dist. collector and direct him to dispose of Ext. P5 application on merits treating it as one filed within the time 'prescribed in that behalf. 13. I am told that proceedings have been initiated against the petitioner in realisation of the arrears of building tax and that they are pending. P6 order of the Dist. collector and direct him to dispose of Ext. P5 application on merits treating it as one filed within the time 'prescribed in that behalf. 13. I am told that proceedings have been initiated against the petitioner in realisation of the arrears of building tax and that they are pending. Since the entire matter has now been remanded to the District Collector for fresh disposal it is only fair that status quo. as regards the recovery of tax as on today be maintained till the disposal of Ext. P5 petition as directed. The Original Petition is disposed of as above. No order as to costs.