Limitation for reassessment notices under sales tax law was not extended by a limited remand direction.

Reassessment notices under the Rajasthan Sales Tax Act, 1954 issued after the ordinary limitation period were not saved by the proviso to section 12(2) where the earlier proceedings had been set aside and the Board of Revenue's remand direction was specific and limited. The Court treated the eight-year bar as continuing to apply to periods already time-barred, because the remand did not authorise fresh notices beyond limitation. The Tribunal was therefore correct in holding the notices for the relevant biennial years to be beyond time and invalid, and the challenge failed.

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Issues: Whether notices issued for reassessment under the Rajasthan Sales Tax Act, 1954, after the expiry of the ordinary limitation period were saved by the proviso to section 12(2) and were therefore valid.

Analysis: The assessments arose out of earlier proceedings that had been set aside and fresh notices were issued pursuant to the order of the Board of Revenue. The controlling question was whether the proviso to section 12(2) applied on the facts so as to lift the eight-year bar. The Court held that the Board's direction was specific and limited, and did not authorise issuance of notices beyond limitation in respect of periods already time-barred. The reassessment notices for the relevant biennial years were therefore not protected by the proviso, and the Tribunal was correct in holding them to be beyond limitation.

Conclusion: The challenge failed. The reassessment notices were held to be time-barred and invalid, and the petitions were dismissed.

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