Original assessment date governs limitation for estate duty reassessment, making late notices time-barred and void.

Section 73A(b) of the Estate Duty Act bars reassessment proceedings begun more than three years after the date of assessment. The expression "date of assessment" is construed as the date of completion of the original assessment, not a later reassessment or appellate event. On that reading, a reassessment notice issued beyond the three-year period is time-barred, without jurisdiction, and cannot sustain further proceedings. The interpretation also prevents repeated reassessments from defeating the statutory limitation period.

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Issues: Whether the reassessment notice issued under the Estate Duty Act was barred by limitation under section 73A(b), and whether the relevant date for computing the three-year period was the date of the original assessment.

Analysis: Section 73A(b) prohibits commencement of reassessment proceedings after three years from the date of assessment. Reading the provision with the scheme of first assessment and reassessment, the expression "date of assessment" was held to mean the date of completion of the original assessment, not the date of any later reassessment. A contrary construction would permit repeated reassessments indefinitely, which would defeat the statutory time bar. Support was drawn from the view that the same expression excludes computation from an appellate order or later proceeding.

Conclusion: The notice issued on 6 September 1974 was beyond the period prescribed by section 73A(b) and was without jurisdiction. It was quashed, and further proceedings pursuant to it were restrained.

Ratio Decidendi: For the purpose of section 73A(b) of the Estate Duty Act, the "date of assessment" means the date of the original assessment, and reassessment proceedings commenced beyond three years from that date are time-barred and void.

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