Statutory limitation bars invalid assessment, and revision based on a void assessment cannot survive.

An assessment completed beyond the statutory limitation period was held to be time-barred and without jurisdiction, because it was made after the last permissible date under the applicable scheme. The void assessment could not be sustained, and the revisional proceedings founded on that invalid assessment also failed. The effect was that both the assessment and the consequential revision were liable to be set aside, with relief going to the assessee. No substantial question of law arose for interference on the facts presented.

---

---

Issues: Whether the assessment order was barred by limitation and, if so, whether the revisional proceedings founded on that assessment could survive.

Analysis: The statutory scheme required the assessment to be completed within three years from the last date prescribed for furnishing the return. On the admitted dates, the assessment could have been framed only up to 30 April 2005, but it was in fact made on 9 April 2007. The order was therefore beyond the prescribed period and could not be sustained. Once the assessment itself was void and without jurisdiction, the later revisional action based on that assessment was also unsustainable.

Conclusion: The assessment was time-barred and invalid, and the revisional order founded on it was also liable to be set aside; the matter was decided in favour of the assessee.

Final Conclusion: No substantial question of law arose for interference, and the State's revision failed.

Ratio Decidendi: An assessment made beyond the statutory limitation period is void and without jurisdiction, and revisional proceedings resting on such an assessment cannot be sustained.

---