Limitation for revised VAT assessments depends on independent determination by the assessing authority, not an Enforcement Wing report.

For limitation under Section 27(1)(a) of the Tamil Nadu Value Added Tax Act, 2006, "determination" requires an independent assessment-oriented decision by the assessing authority against the dealer. An Enforcement Wing inspection or internal report does not itself amount to such determination and therefore does not stop the running of limitation. On the facts noted, the deemed assessment date was 30.06.2012 and the six-year period expired on 30.06.2018, while the revisional notice issued on 27.09.2018 was the first relevant act and was beyond time. The revised assessment orders were consequently time-barred and unsustainable.

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Issues: Whether the revised assessment orders under Section 27(1)(a) of the Tamil Nadu Value Added Tax Act, 2006 were barred by limitation, and whether the Enforcement Wing inspection and report could be treated as the relevant determination so as to save limitation.

Analysis: The deemed assessment date for the assessment years in question was 30.06.2012, and the six-year limitation under the revisional provision expired on 30.06.2018. The Enforcement Wing inspection on 16.12.2016 and report dated 16.04.2018 were held not to amount to determination qua the dealer, because the assessing authority had to independently apply its mind and proceed to assess. The word "determine" in Section 27(1)(a) was understood to mean an effective assessment-oriented decision reached by the assessing authority itself, and not a mere inspection or internal report. The revisional notice issued on 27.09.2018 was therefore the earliest relevant act of proceeding against the dealer, and it was beyond the statutory period.

Conclusion: The revised assessment orders were time-barred and could not be sustained.

Ratio Decidendi: For purposes of Section 27(1)(a) of the Tamil Nadu Value Added Tax Act, 2006, "determination" requires an independent assessment-oriented decision by the assessing authority qua the dealer, and an Enforcement Wing inspection or report does not arrest limitation.

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