Limitation and natural justice challenges fail where VAT proceedings begin in time and supporting documents are not produced.

Limitation under Kerala VAT Act Section 25(1) was not a ground for interference because the notice initiating proceedings was issued within time, even though the assessment order was completed later. The record also showed that an opportunity of hearing had been granted, and the request for further time to produce documents was considered and rejected with reasons, so no denial of natural justice was established. The claim for revision of return also failed because the revised return was not filed with the required audit certificate and supporting documents were not produced despite notice. In the absence of illegality or procedural unfairness, writ interference was unwarranted and the assessment was upheld.

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Issues: Whether the assessment order under the Kerala Value Added Tax Act, 2003 was liable to be interfered with on the grounds of limitation under Section 25(1), denial of opportunity of hearing, and failure to consider the request for revision of return.

Analysis: The notice initiating proceedings under Section 25(1) was issued within the statutory period, and the subsequent assessment could not be invalidated merely because the final order was passed later. The record showed that opportunity of hearing had been given, and the request for additional time to produce documents was considered and rejected for reasons. The claim for revision of return was also not sustainable, as the revised return was not submitted along with the audit certificate as required, and supporting documents were not produced despite notice. In these circumstances, no illegality or procedural unfairness was made out warranting interference in writ jurisdiction, particularly when statutory remedies had not been exhausted.

Conclusion: The assessment order was upheld and the challenge failed.

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