Limitation for initiating sales tax assessment proceedings runs from prior completion proceedings, and delayed commencement is invalid.

Proceedings for assessment under section 18(6)(a) of the Madhya Pradesh General Sales Tax Act were required to be initiated within twelve months of completion of proceedings under section 4-A(1). The first notice dated 12 January 1989 was treated as the initiation date, and no earlier notice or order sheet was shown on record. As completion under section 4-A(1) had occurred on 16 July 1987, initiation was beyond the prescribed period. The separate limitation scheme for completion of assessment under section 18(8) did not cure the delay, so the assessment and revisional orders were barred by limitation.

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Issues: Whether proceedings for assessment under section 18(6)(a) of the Madhya Pradesh General Sales Tax Act, 1958 were initiated within twelve months from the date of completion of proceedings under section 4-A(1), and whether the assessment and revisional orders were therefore barred by limitation.

Analysis: The notice in form XVI dated 12 January 1989 was treated as the first initiation of proceedings under section 18(6)(a). The date of completion of proceedings under section 4-A(1) was 16 July 1987. On the record, no earlier notice or order sheet was produced to show initiation within twelve months. The period prescribed in section 18(6)(a) governs initiation of proceedings, while section 18(8) deals with a different limitation scheme for completion of assessments and did not cure the delay in commencement.

Conclusion: The proceedings under section 18(6)(a) were initiated beyond the prescribed twelve months and were barred by limitation.

Ratio Decidendi: Where a statute requires assessment proceedings to be initiated within a fixed period from completion of proceedings under an earlier provision, commencement beyond that period is invalid and the resulting assessment is barred by limitation, irrespective of a separate limitation period for completion of assessment.

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