Limitation and ante-dated reassessment records led to quashing of the reassessment and consequential revisional action.

Section 42(2) of the Jharkhand Value Added Tax Act required reassessment to be completed within two years from the remand order. The record showed unexplained gaps in the order sheet, delayed first effective action, and an incoherent sequence of hearing entries that did not support the asserted disposal date. The absence of any specific denial of ante-dating, together with delayed service of the demand notice, supported the finding that the reassessment order had been shown as timely only by ante-dating it. The reassessment was therefore treated as beyond limitation, void ab initio, and the revisional order founded on it was also unsustainable.

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Issues: Whether the reassessment order was passed beyond the period of limitation by being ante-dated and, if so, whether the revisional order could survive.

Analysis: The limitation under Section 42(2) of the Jharkhand Value Added Tax Act, 2005 required the reassessment to be completed within two years from the remand order. The order-sheet showed unexplained gaps, the first effective step was taken only after a long delay, and the date sequence of hearing entries did not coherently support the asserted date of disposal. The absence of a specific denial to the allegation of ante-dating, coupled with the delayed service of demand notice and the surrounding record, supported the conclusion that the reassessment order had been shown as timely only by ante-dating it.

Conclusion: The reassessment order was held to be beyond limitation, ante-dated, and void ab initio, and the revisional order based on it could not be sustained.

Ratio Decidendi: A reassessment order purportedly passed within the statutory limitation period but shown by the record to be ante-dated and unsupported by a coherent procedural trail is void ab initio and liable to be quashed, along with consequential revisional action.

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