Escaped turnover reassessment and notice service by registered post were treated as valid through substantial compliance.

Escaped turnover reassessments were held to fall within the limitation under section 19(1) where the dealer had not filed returns and best judgment assessment was available. The pre-assessment notice was issued in time, and the dispute turned on service alone. On the facts, dispatch of the notice by registered post to the dealer's known addresses, coupled with non-acceptance of the cover and conduct indicating avoidance, amounted to substantial compliance with the service requirement under section 55B(c). The limitation challenge therefore failed, and the assessments were sustained.

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Issues: Whether the reassessments were barred by limitation and whether the pre-assessment notice was duly served so as to sustain proceedings for escaped turnover.

Analysis: The dealer had not filed returns, enabling best judgment assessment under the Act. Since the turnover was treated as escaped turnover, the limitation under section 19(1) applied. The pre-assessment notice was issued within time, and the only controversy was service. On the facts found, the notice was sent by registered post to the dealer's known addresses, but the cover was not accepted and the conduct showed conscious avoidance of notice. In that situation, the Court held that there was substantial compliance with the statutory requirement of service under section 55B(c). The finding that the assessments were within limitation was therefore supported by law and fact.

Conclusion: The challenge to the assessments on limitation failed, and the revision petitions were liable to be dismissed in favour of the Revenue.

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