Assessment as a composite process defeated the limitation challenge to tax notices issued within time.

Limitation under Section 24(5) of the Puducherry Value Added Tax Act, 2007 was tested against the meaning of "assessment" in Section 2(e), and the Court treated assessment as a composite process including notices, summons and enquiry, not only the final assessment order. On that reading, once the assessing authority commenced proceedings within the prescribed period by issuing notices or summons calling for documents, the later completion of assessment was not time-barred merely because the final order came after three years. The summons issued on 07.11.2014 and 04.01.2016 were therefore within time, and the limitation objection failed.

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Issues: Whether the impugned notices and pre-assessment notice were barred by limitation under Section 24(5) of the Puducherry Value Added Tax Act, 2007.

Analysis: Section 2(e) defines assessment as the determination of turnover to ascertain tax liability by self-assessment, reassessment, scrutiny assessment, and best judgment assessment. Reading Section 24(5) with that definition, assessment is a composite process and not merely the final order of assessment. Once the assessing authority initiates the process within the prescribed period by issuing notices or summons calling for documents and enquiry, the later completion of assessment does not become time-barred merely because the final order is passed after three years. The summons issued on 07.11.2014 and 04.01.2016 commenced assessment proceedings within time for the relevant assessment years.

Conclusion: The limitation objection failed, and the impugned notices were held to be within time and valid.

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