Limitation for tax assessment revision barred a belated notice issued after the statutory five-year period expired.

Revision of assessment under Section 16 of the Tamil Nadu General Sales Tax Act, 1959 had to be initiated within five years from the date of the final assessment order. For assessment year 2005-2006, the final assessment order was dated 10.08.2007, so the revisional power expired on 09.08.2012. Because the first revision notice was issued only on 27.03.2013, it was beyond the statutory limitation period. The revision was therefore barred by limitation and the impugned order was liable to be quashed.

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Issues: Whether the revision of assessment was barred by limitation under Section 16 of the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The assessment year in question was 2005-2006. Under Section 16 of the Tamil Nadu General Sales Tax Act, 1959, as applicable to the relevant period, revision of assessment could be made within five years from the date of the final assessment order. The final assessment order was dated 10.08.2007, so the power to revise had to be exercised before 09.08.2012. The first revision notice was issued only on 27.03.2013, which was beyond the statutory period.

Conclusion: The revision of assessment under Section 16(1) was barred by limitation and the impugned order was liable to be quashed.

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