ORDER : Harsha Devani, J. 1. The appellant dealer has challenged the order dated 21.8.2006 passed by the Gujarat Value Added Tax Tribunal at Ahmedabad (hereinafter referred to as the "Tribunal") in Revision Application No. 30 of 2005 whereby the Tribunal has dismissed the revision application and confirmed the order passed by the Deputy Commissioner of Sales Tax. 2. The appellant is a company registered under the Companies Act, 1956. During the relevant year, the appellant had carried out two works contracts with BPCL and L & T Limited for which it had applied for composition under section 55(A) of the Gujarat Sales Tax Act, 1969, (hereinafter referred to as the "Act") and also obtained permission for composition in Form 35(B). The appellant submitted all the monthly, quarterly and annual returns and also paid sales tax accordingly. Subsequently, the Sales Tax Officer, without cancelling the composition permission granted to the appellant, assessed it as if such composition permission was never issued to the appellant. The revisional authority, subsequently, issued notice in Form No. 49 under section 67 of the Act, proposing to cancel the composition permission orders previously granted to the appellant. The appellant opposed the said proceedings on the ground of limitation. The revisional authority, however, passed an order cancelling the composition permission granted to the appellant. 3. The appellant carried the matter in appeal before the Tribunal, which by the impugned order dismissed the revision application of the appellant holding that the exercise of revisional powers was not time barred as the period of limitation would start when any purported mischief is noticed by the Commissioner. 4. Being aggrieved, the appellant has preferred this appeal. 5. This court, by an order dated 11.4.2007, had admitted the appeal on the following two questions of law: "(1) Whether on the facts and circumstances of the case, the Appellate Tribunal was right in holding that the notice for revision was not time barred as period of limitation would commence from the knowledge of purported mischief of Government record? (2) Whether on the facts and circumstances of the case, the Appellate Tribunal was right in holding that the Appellate Tribunal had not exceeded its jurisdiction in giving findings on the aspects, which were beyond the scope of the appeal and without there being any material on record or investigation thereto?" 6. Mr. (2) Whether on the facts and circumstances of the case, the Appellate Tribunal was right in holding that the Appellate Tribunal had not exceeded its jurisdiction in giving findings on the aspects, which were beyond the scope of the appeal and without there being any material on record or investigation thereto?" 6. Mr. Tanvish Bhatt, learned advocate, for the appellant invited the attention of the court to the facts of the case to submit that the order permitting composition was passed on 19.12.2000, whereas the same was taken in revision by issuance of notice dated 2.2.2005 which is clearly beyond the period of limitation prescribed under section 67 of the Act. Referring to the provisions of section 67 of the Act, it was pointed out that the limitation prescribed therein in a case where the Commissioner of his own motion takes an order passed by any officer appointed under section 27 to assist him, is three years from the date of such order, whereas in the facts of the present case while the composition order was passed on 19.12.2000, notice under section 67 of the Act was issued on 2.2.2005, which is clearly beyond the period of limitation prescribed therefor. It was submitted that the Tribunal was, therefore, not justified in holding that the period of limitation would be the date of knowledge of the Deputy Commissioner of Sales Tax and if that is considered then the revision application is well within three years and therefore, it cannot be treated being barred by limitation. 6.1 As regards the second question, it was submitted that the Tribunal while considering the matter on merits had exceeded its jurisdiction in giving findings on the aspects which were beyond the scope of appeal and without there being any material on record or investigation thereto. It was, accordingly, submitted that the impugned order being inconsistent with the provisions of section 67(1)(a) of the Act, deserves to be quashed and set aside and the questions are required to be answered in favour of the appellant. 7. Opposing the appeal, Ms. Maithili Mehta, learned Assistant Government Pleader supported the impugned order by reiterating the reasoning adopted by the Tribunal. 7. Opposing the appeal, Ms. Maithili Mehta, learned Assistant Government Pleader supported the impugned order by reiterating the reasoning adopted by the Tribunal. Referring to the findings recorded by the Tribunal, it was submitted that had there been fairness and bona fide on the part of the appellant, the appellant could have made an application stating that there was a delay in submission of application for composition permission and the delay may be condoned in which case the matter would have been different if that procedure was adopted. It was submitted that the procedure adopted by the appellant should not be encouraged and that in any case the ground for cancellation of the composition permission was not illegal. It was argued that the material condition for such permission was that the applications for composition permission ought to have been filed within one month and that since the applications were not filed within one month, the composition permission could not have been granted. Therefore, the grant of composition permission itself was illegal. 7.1 The learned Assistant Government Pleader further pointed out that the Tribunal has thought it fit that it would not be just, legal and equitable to encourage dishonesty by giving technical benefit to the appellant on the issue of limitation, more so, when the appellant was not entitled to any technical benefit as such. It was submitted that in the light of these facts the Tribunal was justified in holding that the date of knowledge of the Deputy Commissioner of Sales Tax is required to be considered for the purpose of computing of the period of limitation of three years. It was, accordingly, urged that the appeal being devoid of merits deserves to be dismissed. 8. As noted hereinabove, the appeal has been admitted on two questions. However, if the first question is answered in the negative that is in favour of the appellant and against the respondent, it would not be necessary to enter into the merits of the second question. 9. The controversy that has been raised by the first question is as to whether the Tribunal was right in holding that the notice for revision was not time barred as the period of limitation would commence from the knowledge of the purported mischief of the Government record. 9. The controversy that has been raised by the first question is as to whether the Tribunal was right in holding that the notice for revision was not time barred as the period of limitation would commence from the knowledge of the purported mischief of the Government record. In the present case, the revisional authority has exercised powers under section 67 of the Act for taking the composition order in revision and setting the same aside. It would, therefore, be germane to refer to the provisions of section 67 of the Act, which provides for "revision". Clause (a) of sub-section (1) of section 67 of the Act, to the extent the same is relevant for the present purpose, provides that subject to the provisions of section 66 and to any rules which may be made in this behalf, the Commissioner of his own motion within three years or on an application made to him within one year from the date of any order passed by any officer appointed under section 27 to assist him, may call for and examine the record of any such order and pass such order thereon as he thinks just and proper within twelve months from the date of service of notice for revision. 10. From the language employed in the section 67 of the Act, it is amply clear that the period of limitation of three years commences from the date any order has been passed by any officer appointed under section 27 to assist the Commissioner. In the present case, such order is the composition order dated 19.12.2000. In the light of the clear language of clause (a) of sub-section (1) of section 67 of the Act, the period of three years for exercising powers under section 67(1)(a) of the Act would commence from the date of such order, that is, from 19.12.2000. Therefore, such period would come to an end on 18.12.2003. In the present case, it is an undisputed position that the Commissioner had taken the order dated 19.12.2000 in revision by issuing notice dated 2.2.2005. Evidently therefore, the exercise of powers under section 67 of the Act by the Commissioner was beyond the period of limitation. 11. Therefore, such period would come to an end on 18.12.2003. In the present case, it is an undisputed position that the Commissioner had taken the order dated 19.12.2000 in revision by issuing notice dated 2.2.2005. Evidently therefore, the exercise of powers under section 67 of the Act by the Commissioner was beyond the period of limitation. 11. The Tribunal, in the impugned order has proceeded on the basis that having regard to the facts and circumstances of the case, it would be equitable to consider that the date of knowledge of the Deputy Commissioner of Sales Tax is the starting point of limitation. In this regard it may be germane to refer to the following extract from the decision of the Supreme Court in the case of Vodafone International Holdings BV v. Union of India, (2012) 6 SCC 613 : "401. Viscount Simon quoted with approval a passage from Rowlatt, J. expressing the principle in the following words: "... in a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used. [Cape Brandy Syndicate v. IRC, (1921) 1 KB 64, at p. 71(Rowlatt, J.).]" 402. In Ransom v. Higgs, (1974) 1 WLR 1594, Lord Simon stated that: (WLR pp. 1616 H-617 B) "... It may seem hard that a cunningly advised taxpayer should be able to avoid what appears to be his equitable share of the general fiscal burden and cast it on the shoulders of his fellow citizens. But for the Courts to try to stretch the law to meet hard cases (whether the hardship appears to bear on the individual taxpayer or on the general body of taxpayers as represented by the Inland Revenue) is not merely to make bad law but to run the risk of subverting the rule of law itself." (emphasis supplied) 403. The proper course in construing revenue Acts is to give a fair and reasonable construction to their language without leaning to one side or the other but keeping in mind that no tax can be imposed without words clearly showing an intention to lay the burden and that equitable construction of the words is not permissible (Ormond Investment Co. The proper course in construing revenue Acts is to give a fair and reasonable construction to their language without leaning to one side or the other but keeping in mind that no tax can be imposed without words clearly showing an intention to lay the burden and that equitable construction of the words is not permissible (Ormond Investment Co. v. Betts, 1928 AC 143, p. 162), a principle entrenched in our jurisprudence as well." 12. Thus, it is a settled legal position of law that in a taxing statute one has to go by the clear language of the statute and equity has no role to play while interpreting a taxing statute. One can only look fairly at the language used. To try to stretch the law to meet hard cases is not merely to make bad law but to run the risk of subverting the rule of law itself. The Tribunal, in the present case, to meet with a hard case, has tried to stretch the law by interpreting the provisions of section 67 of the Act in a manner not contemplated by the clear language of the statute, which is clearly not permissible in law. The interpretation made by the Tribunal on the basis of equitable considerations, that the period of limitation for exercise of powers under section 67 of the Act would commence from the date of knowledge of the Deputy Commissioner of Sales Tax, is inconsistent with the language of section 67(1)(a) of the Act, which clearly and unambiguously provides for a period of limitation of three years from the date of the order, for invoking revisional jurisdiction. The Tribunal, therefore, was not justified in holding that the notice for revision was not time barred as the period of limitation would commence from the knowledge of purported mischief of Government record. 13. The first question, therefore, stands answered in the negative, that is, in favour of the appellant and against the respondent. 14. In the light of the fact that the revisional proceedings have been held to be time barred, it would not be necessary to enter into the merits of the controversy raised by the second question, which is accordingly, left unanswered. 15. For the foregoing reasons, the appeal succeeds and is, accordingly, allowed. 14. In the light of the fact that the revisional proceedings have been held to be time barred, it would not be necessary to enter into the merits of the controversy raised by the second question, which is accordingly, left unanswered. 15. For the foregoing reasons, the appeal succeeds and is, accordingly, allowed. The impugned order dated 21.8.2006 passed by the Tribunal as well as the order dated 5.4.2005 passed by the Deputy Commissioner of Sales Tax, Appeal-4, Vadodara, are hereby quashed and set aside and the composition order dated 19.12.2000 is hereby restored.