Limitation on VAT assessments bars completion beyond the statutory period; time-barred assessment portion was set aside.

An assessment completed beyond the four-year limitation period prescribed for completion of assessment under the A.P. VAT Act was invalid to the extent it covered the time-barred period. The court accepted the limitation objection because the assessment for April 2005 to May 2009 extended beyond the statutory period, and the respondents conceded that position. The assessment for that period was therefore held illegal and the assessment order was set aside only to that extent.

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Issues: Whether the assessment for the period from April 2005 to May 2009 was barred by limitation under Section 21(4) of the A.P. VAT Act, 2005.

Analysis: Section 21(4) empowers the competent authority to complete assessment within four years from the end of the relevant assessment period. The challenged assessment covered a period extending beyond that four-year limit, and the respondents also conceded that the assessment for April 2005 to May 2009 was beyond the prescribed period. The limitation objection was therefore accepted only for that part of the assessment.

Conclusion: The assessment for the period from April 2005 to May 2009 was held illegal and barred by limitation, and the assessment order was set aside to that extent.

Ratio Decidendi: An assessment made beyond the statutory period of limitation prescribed for completion of assessment is invalid to the extent it covers the time-barred period.

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