Limitation for reassessment depends on the correct assessment year; calendar-year accounting pushed the notice within time.

A reassessment notice under section 12 of the Rajasthan Sales Tax Act, 1954 was held to be within limitation because the dealer's accounting year was the calendar year and the statutory definition of "previous year" made the corresponding assessment year 1989-90, not 1988-89. On that basis, the notice dated 15 March 1995 fell within the permissible reopening period. The limitation objection therefore failed, and the reassessment challenge was rejected.

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Issues: Whether the reassessment notice issued under section 12 of the Rajasthan Sales Tax Act, 1954 for the calendar accounting year 1 January 1988 to 31 December 1988 was barred by limitation on the footing that the relevant assessment year was 1988-89.

Analysis: The accounting year of the dealer was the calendar year, and the statutory definition of "previous year" permitted the assessment year to run from 1 April following the end of that accounting year. On that basis, the assessment year corresponding to the calendar year 1988 was 1989-90, not 1988-89. The reassessment notice dated 15 March 1995 therefore fell within the permissible period for reopening.

Conclusion: The reassessment was not time-barred, and the challenge to the notice failed.

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