Limitation after remand still runs from the original assessment, so time-barred revision notices cannot survive.

Limitation continued to apply despite the earlier remand, because the statutory time bar was measured from the original assessment order and could not be bypassed by relying on quashed proceedings. The assessee had been expressly permitted to raise limitation after remand, and the authority's fresh notice and consequential revisional order were issued beyond five years from the original assessment. As the impugned action was time-barred, the notice and order could not be sustained and were set aside.

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Issues: Whether the impugned notice and consequential order revising the assessment were liable to be set aside as being beyond the period of limitation, despite the matter having earlier been remitted for fresh consideration.

Analysis: The assessment had originally been completed long before the impugned notice was issued. Although earlier orders were set aside and the matter was remitted, liberty had been expressly reserved to the assessee to raise all available grounds, including limitation. The Court held that remand did not extinguish the statutory limitation period and that the authority could not bypass limitation by relying on the earlier quashed proceedings. Since the impugned action was taken beyond five years from the original assessment order, the plea of limitation was available and the subsequent notice and order could not be sustained.

Conclusion: The challenge succeeded. The impugned notice and consequential order were set aside as time-barred.

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