Reasonable-time limitation in tax enforcement proceedings bars unexplained delay after inspection or verification, and repeated summonses cannot revive them.

Proceedings under Section 67 of the Kerala Value Added Tax Act were held unsustainable where the department acted after an unreasonable delay following inspection and verification of accounts. The court treated limitation as running from detection of the offence and held that detection required prompt action within a reasonable time, even though the statute no longer contained an express limitation period. Repeated summonses could not cure unexplained departmental delay or extend time indefinitely, so the proceedings were set aside.

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Issues: Whether proceedings initiated under Section 67 of the Kerala Value Added Tax Act, 2003 were liable to be quashed for having been commenced and pursued after an unreasonable delay and beyond the permissible period of limitation.

Analysis: The proceedings arose from an inspection conducted in 2010, followed by verification of books of account and a much later summons in 2015. The limitation applicable to Section 67 was treated as running from detection of the offence, and detection was held to require action within a reasonable time from inspection or verification. Even where the statute later ceased to specify an express limitation, the proceedings were required to be completed within a reasonable period. Repeated summonses could not cure the departmental delay or extend time indefinitely.

Conclusion: The proceedings were unsustainable for want of reasonable promptness and were set aside; the writ petition was allowed.

Ratio Decidendi: Where a tax-enforcement provision requires detection and completion of proceedings within a reasonable period, the department must act promptly from inspection or verification, and unexplained delay cannot be cured by issuing repeated summonses.

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