Limitation on tax revision proceedings barred retrospective extension, and completed assessments could not be reopened after expiry.

Revision of assessment under the Tamil Nadu Value Added Tax Act had to be initiated within five years from the original assessment order. As the self-assessments were completed on 30.06.2012 and revision proceedings began only on 24.11.2017, the Madras HC held the proceedings time-barred and set aside the revised assessment orders. The Court followed the earlier view that an amendment extending the limitation period could not be applied retrospectively to completed assessments unless the legislature clearly provided otherwise.

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Issues: Whether the revision assessment orders were barred by limitation for having been initiated beyond the five-year period under the Tamil Nadu Value Added Tax Act.

Analysis: The self-assessment for the relevant assessment years had been completed on 30.06.2012. Under Section 27 of the Tamil Nadu Value Added Tax Act, as applicable during the relevant period, revision of assessment had to be initiated within five years from the date of the original assessment order. The revision proceedings were commenced only on 24.11.2017, after the expiry of the five-year period. The Court followed the earlier view that the amended provision enhancing the limitation period could not be applied retrospectively to completed assessments.

Conclusion: The revision proceedings were time-barred and the impugned assessment orders were liable to be set aside.

Final Conclusion: The writ petitions succeeded, and the revised assessment orders were quashed as having been issued beyond the permissible period of limitation.

Ratio Decidendi: A revision of assessment under the applicable tax statute must be initiated within the prescribed limitation period, and an amendment extending that period operates prospectively unless the legislature clearly provides otherwise.

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