Limitation barred VAT revision where notice was issued after the five-year statutory period had expired.

Revision of an assessment under the Tamil Nadu Value Added Tax Act was barred because the statute allowed revision only within five years from the assessment order. The original assessment was completed on 27.04.2010, but the revision notice was issued on 10.03.2016, after the limitation period had expired. The fact that the alleged purchase omission came to light in 2014 did not extend or save the statutory time limit. The revision proceedings were therefore unsustainable, and the impugned order was set aside in favour of the assessee.

---

---

Issues: Whether the revision notice and consequential revision of assessment were barred by limitation under the Tamil Nadu Value Added Tax Act.

Analysis: The original assessment was completed on 27.04.2010. Section 27 permitted revision only within five years from the date of the assessment order. The notice for revision was issued on 10.03.2016, after the expiry of the five-year period. The alleged purchase omission having come to light in 2014 did not extend or save the statutory period, and the challenge was governed by the limitation fixed by the statute. The revision was therefore unsustainable once the prescribed period had expired.

Conclusion: The revision proceedings were barred by limitation and the impugned order was set aside in favour of the assessee.

---