Limitation in assessment proceedings bars completion beyond the prescribed period where binding precedent already settles the issue.

Assessment completed beyond the prescribed three-year period was held unsustainable on limitation grounds, as the only surviving issue concerned the validity of the assessment order. The parties accepted that the point was already settled by binding precedent, and the Court applied that prior decision to conclude that the delayed assessment could not stand. The matter was resolved in favour of the assessee, and the appeal was disposed of in line with the earlier authoritative ruling governing limitation in assessments under the Act.

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Issues: Whether the assessment for the year 2005-06, completed beyond three years, was barred by limitation.

Analysis: The only issue surviving for consideration was the validity of the assessment order on the ground of limitation. The parties agreed that the issue was no longer res integra and had already been concluded by the binding decision relied upon by the Court.

Conclusion: The assessment beyond the prescribed period of three years was not sustainable. The issue was decided in favour of the assessee.

Final Conclusion: The appeal succeeded and was disposed of in terms of the earlier binding decision governing limitation in assessments under the Act.

Ratio Decidendi: Where the legal issue of limitation in completing assessment is already concluded by binding precedent, the assessment made beyond the prescribed period cannot be sustained.

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