Assessment limitation applied to earlier years, and the order passed after 30 April 2001 was held time-barred.

The amended limitation provision for assessment was treated as applicable to earlier assessment years, and assessments for years up to 1997-98 had to be completed within the period recognised by the Court. Applying its earlier identical rulings, the High Court held that an assessment order passed after 30 April 2001 could not be validly made for those years, and the order was time-barred.

---

---

Issues: Whether, in view of the amendment prescribing a three-year limitation period for assessment, an assessment order for assessment years up to 1997-98 could validly be passed after 30 April 2001.

Analysis: The amended provision governing assessment limitation was held to apply so that, for assessment years prior to insertion of the limitation under the relevant sales tax law, assessments had to be finalised within the period recognised by the Court. The issue was treated as already settled by the Court in earlier identical matters, where it was held that assessments relating to those years could not be validly completed beyond 30 April 2001.

Conclusion: The issue was decided against the appellants and in favour of the assessee; the assessment order was held time-barred.

---