Unreasonable delay in completing tax assessments can render them time-barred when no stay justifies the delay.

Assessment orders under the Punjab General Sales Tax Act were completed long after the relevant assessment years, and the delay was not justified by pending litigation on sugarcane taxability. The record did not support the claim that the proceedings were kept in abeyance at the assessees' request, and there was no interim stay covering the assessment years in question. Mere pendency of other matters could not justify an indefinite delay where the statute did not permit it. The Tribunal therefore treated the assessments as time-barred, and the appeals disclosed no substantial question of law.

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Issues: Whether the assessment orders framed under Section 11(3) of the Punjab General Sales Tax Act, 1948 were liable to be set aside as time-barred for having been passed after an unreasonable delay and whether any substantial question of law arose for consideration in the appeals.

Analysis: The assessments in the connected matters were completed long after the close of the relevant assessment years. The plea that the proceedings had remained pending due to litigation on the taxability of sugarcane and were kept in abeyance at the request of the assessees was not supported by the record. There was no interim stay covering the assessment proceedings for the years in question, and the mere pendency of other matters did not justify an indefinite delay in completing assessment. The Tribunal had therefore correctly applied the governing principle that assessment cannot be left pending beyond a reasonable period where the statute does not justify such delay.

Conclusion: The assessments were rightly held to be time-barred, and no substantial question of law arose. The appeals failed.

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