Failure to disclose material turnover particulars can extend reassessment limitation under sales tax law.

Reassessment under Section 24 of the Delhi Sales Tax Act, 1975 was held to fall within the extended six-year period where the dealer failed to fully disclose material particulars of turnover. Because Rule 23A required disclosure of the purchase price of goods used for purposes other than those specified in the registration certificate, the assessee's return was deficient in not disclosing the relevant purchase price of goods covered by statutory forms but not so used. On the facts, the authorities and Tribunal were justified in treating the omission as failure to disclose fully material particulars, so the limitation objection failed and the reassessment was not time-barred.

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Issues: Whether reassessment under Section 24 of the Delhi Sales Tax Act, 1975 was barred by limitation or was validly initiated within the extended six-year period on the ground that the assessee had failed to disclose fully the particulars of its turnover.

Analysis: Section 24(1) of the Delhi Sales Tax Act, 1975 permits reopening within six years where the dealer has concealed, omitted, or failed to disclose fully the particulars of turnover, and within four years in any other case. Rule 23A of the Delhi Sales Tax Rules, 1975 required disclosure of the purchase price of goods utilized for purposes other than those specified in the registration certificate. The return filed by the assessee did not disclose the purchase price of goods covered by statutory forms that were not used for the specified purpose, and the material on record showed non-disclosure of facts necessary for correct assessment. On that basis, the Tribunal and the authorities below were justified in treating the case as one of failure to disclose fully material particulars.

Conclusion: The reassessment was within the extended period of six years and was not time-barred. The objection based on limitation failed.

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