Time-barred reassessment notices under the Rajasthan Sales Tax Act were void for lack of jurisdiction after the five-year limit expired.

Reassessment notices under section 12 of the Rajasthan Sales Tax Act were held to be invalid where issued after the post-amendment five-year limitation period. The amended provision required reassessment to be initiated within five years from the last date of the relevant assessment year; for assessment year 1988-89, that period expired on 31 March 1994. Because the notices were issued on 15 March 1995, the assessing authority lacked jurisdiction to commence reassessment. The proceedings were therefore time-barred, void ab initio, and the revisions were dismissed.

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Issues: Whether reassessment notices issued under section 12 of the Rajasthan Sales Tax Act after expiry of the prescribed five-year period were valid and could sustain the reassessment proceedings.

Analysis: The reassessment proceedings were initiated on 15 March 1995 for assessment year 1988-89. After the 1991 amendment to section 12 of the Rajasthan Sales Tax Act, the assessing authority could initiate reassessment only within five years from the last date of the relevant assessment year. The limitation for assessment year 1988-89 expired on 31 March 1994. The notices having been issued after expiry of that period, the assessing authority lacked jurisdiction to commence reassessment.

Conclusion: The initiation of reassessment proceedings was time-barred, without jurisdiction, and void ab initio; the revisions were dismissed.

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