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2014 (7) TMI 968 - HC - VAT and Sales TaxValidity of assessment order - Bar of limitation - Held that:- Limitation prescribed under section 39 is as to the "making" of the assessment and not to "initiation" thereof. The observation of the revisional authority that "made" did not mean "completed" or "signed" can not be accepted. The same is contrary to the plain meaning of the expres sion "made" - section 18(1) provides for limitation for initiating the reassessment while section 19(2) prescribes limitation for completing the assessment. In the present case, it is clear that completion of reassessment, i.e., passing of the order of reassessment is beyond the limitation prescribed under section 19(2) - Decided in favour of assessee.
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