Limitation for Wealth-tax assessment orders runs from when the order is made, not when it is served on the assessee.

For limitation under section 17A(1)(a) of the Wealth-tax Act, an assessment order is treated as made when it is signed or otherwise finalised as a quasi-judicial order, not when it is served on the assessee. The statute does not require communication within the limitation period, so the distinction between making an order and serving it is material. Authorities dealing with administrative orders or with the term "issued" in different statutory contexts were held inapplicable. On that basis, the assessment order was validly made on the date it purported to have been made and was not time-barred.

---

---

Issues: Whether an assessment order under the Wealth-tax Act is treated as made only when served on the assessee for the purpose of limitation under section 17A(1)(a).

Analysis: The prescribed limitation in section 17A(1)(a) turns on when the assessment order is made, not when it is communicated. An assessment order is a quasi-judicial order, and the statute does not require service within the limitation period. The distinction between making an order and serving it was held material, and the authorities concerning administrative orders and the expression "issued" in a different statutory setting were held inapplicable.

Conclusion: The assessment order was validly made on the date it purported to have been made, not on the date of service, and was not barred by limitation.

Ratio Decidendi: For limitation under section 17A(1)(a) of the Wealth-tax Act, an assessment order is made when it is signed or otherwise finalised as an assessment order, and service on the assessee is not a condition for its being made within time.

---