Appeal limitation under sales tax law runs from service of the reasoned assessment order, not the demand notice alone.

Limitation for an appeal against an assessment begins only when the assessee is served with the assessment order recording reasons, not merely with the demand notice. Under the amended Karnataka Sales Tax Rules, the assessing authority must briefly record reasons in writing and furnish a copy of the order where the assessed turnover differs from the return, because meaningful challenge is possible only after notice of the reasons for assessment. On that basis, appeals filed after service of the assessment orders were not time-barred, and the rejection of the appeals on limitation grounds was set aside for reconsideration on merits.

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Issues: Whether the period of limitation for filing appeals against assessment orders commenced from service of the demand notices or only from service of the copies of the assessment orders recording reasons.

Analysis: The period of limitation for an appeal under section 20 of the Karnataka Sales Tax Act, 1957, was held to begin when the assessee is served with the assessment order containing the reasons for the assessment, because only then does the assessee have notice of the assessment and a meaningful opportunity to challenge it. Under amended rule 22(1) of the Karnataka Sales Tax Rules, 1957, where the turnover determined differs from the return, the assessing authority is required to record reasons briefly in writing and furnish a copy to the assessee. Since the assessment orders were not served and the assessee received the copies only on 1 February 1972, the appeals could not be treated as time-barred from the date of the demand notices.

Conclusion: The limitation period commenced on service of the assessment orders, not on service of the demand notices, and the appeals were within time. The rejection of the appeals as barred by limitation was , and the matter required restoration for disposal on merits.

Final Conclusion: The revisional challenges succeeded, the limitation objection failed, and the appeals were directed to be entertained and decided afresh according to law.

Ratio Decidendi: Limitation for an appeal against an assessment starts only upon service of the assessment order recording reasons where such service is mandated, not upon service of a demand notice alone.

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