Limitation for appeal runs from a superseding revised assessment order, not the original order, when the earlier assessment ceases to operate.

Where a revised assessment order is issued after the original order is superseded, limitation for appeal runs from the revised order and not from the earlier assessment. The revised order, made at the dealer's request after adjustment of payment already made and reducing tax and penalty, displaced the original order for computing the appeal period. The appellate authority was wrong to treat the appeal as time-barred by reference to the original order. As the appeal was filed within the statutory period counted from the revised assessment order, the limitation objection failed and the appeal was entitled to be entertained on merits.

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Issues: Whether the appeal was barred by limitation on the basis of the original assessment order, or whether limitation had to be computed from the revised assessment order that superseded the earlier order.

Analysis: The assessment originally made was later revised at the dealer's request after adjustment of payment already made, and the revised order reduced the tax and penalty. Once a fresh revised order was issued, the earlier assessment order ceased to operate for the purpose of computing limitation. The appellate authority was therefore not correct in treating the appeal as time-barred by reckoning the period from the date of the original order instead of the revised order. Since the appeal had been filed within the statutory period counted from the revised assessment order, it was liable to be entertained.

Conclusion: The limitation objection was rejected, and the appeal was held to be within time and fit to be entertained on merits.

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