Reasonable time for tax assessments bars extreme delay; extended limitation provisions cannot revive already time-barred proceedings.

Although the sales tax statute prescribed no express limitation period for completing assessments, the assessments still had to be made within a reasonable time. Where the assessee did not file annual returns and no satisfactory explanation was given for the prolonged delay, a delay of more than five or six years could not be treated as reasonable; assessments completed after about 18 to 19 years were therefore barred by unreasonable delay. The extended limitation provisions relied on by the Revenue did not apply, because the assessments had already become time-barred before those provisions could operate. The revisions were accordingly rejected in favour of the assessee.

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Issues: Whether the assessment orders completed after an inordinate delay of more than 18 to 19 years were barred as not made within a reasonable time, and whether the extended limitation provisions under the sales tax statute applied.

Analysis: No statutory period of limitation was provided for completion of the assessments, but assessments had still to be completed within a reasonable time. The assessee had not filed annual returns, and no sufficient explanation was shown for the prolonged delay in completing the assessments. On the facts, a delay of more than five or six years could not be treated as reasonable, and the assessments here were made only after about 18 to 19 years. The provisions relied upon for extending limitation did not apply because the assessments were already barred by unreasonable delay long before the relevant extension provisions came into play.

Conclusion: The assessments were barred by delay beyond a reasonable time and the extension provisions did not assist the Revenue. The revisions were rightly rejected, in favour of the assessee.

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