Limitation for tax revision turns on the revisional notice date, not inspection or voluntary payment during inspection.

Revisional assessments under the Tamil Nadu Value Added Tax Act, 2006 were held time-barred because the six-year period under Section 27(1)(a) runs from the date of assessment, and the statutory revision process begins only when the revisional notice is issued. Inspection by itself, or payment of tax during inspection, does not amount to commencement of revision proceedings or complete the determination of escaped turnover or incorrect input tax credit. As the revisional notice was issued after expiry of the prescribed period, the consequential revised assessment orders could not be sustained and were quashed.

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Issues: Whether the revisional assessment orders under the Tamil Nadu Value Added Tax Act, 2006 were barred by limitation, and whether the date of inspection or tax payment could be treated as the commencement of revision proceedings instead of the date of the revisional notice.

Analysis: The assessments for the relevant years had already attained deemed completion. For revision on the ground of escaped turnover or wrong availment of input tax credit, Section 27(1)(a) of the Tamil Nadu Value Added Tax Act, 2006 required the assessing authority to proceed within six years from the date of assessment. The Court held that the statutory exercise of determining escaped turnover and assessing tax begins only with issuance of the notice proposing revision. Inspection by itself, or payment of tax before enforcement officials, does not amount to completion of the statutory determination required for revision. Since the revisional notice was issued after expiry of six years, the consequential orders could not be sustained.

Conclusion: The revision was barred by limitation and the impugned assessment orders were invalid.

Final Conclusion: The writ petitions succeeded on the ground of limitation and the revised assessments were quashed.

Ratio Decidendi: For revision under Section 27(1)(a) of the Tamil Nadu Value Added Tax Act, 2006, the relevant reckoning date is the date of issuance of the revisional notice, and not the date of inspection or voluntary payment during inspection.

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