COVID-19 exclusion extended limitation for reassessment, making the time-bar objection fail under the Punjab VAT framework.

Section 29(7) of the Punjab VAT Act, 2005 allows amendment of an assessment within three years from the original assessment order, subject to prior approval of the Commissioner. In computing that limitation, the COVID-19 period from 15.03.2020 to 28.02.2022 was excluded in line with the Supreme Court's directions for judicial and quasi-judicial proceedings. On that basis, the reassessment was treated as timely and the objection that it was time-barred was rejected.

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Issues: Whether the reassessment order was barred by limitation under Section 29(7) of the Punjab VAT Act, 2005 in view of the COVID-19 period being excluded.

Analysis: Section 29(7) permits amendment of an assessment within three years from the date of the original assessment order, subject to prior permission of the Commissioner. The period of limitation was considered in light of the Supreme Court orders excluding the period from 15.03.2020 to 28.02.2022 for all judicial and quasi-judicial proceedings under general and special laws. On that basis, the COVID-19 period was treated as excluded while computing the three-year limitation.

Conclusion: The reassessment order was held to be within limitation and the objection based on time-bar was rejected.

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