https://www.taxtmi.com/caselaws?id=99716 The thirty-six month limitation in the second proviso to section 12(6) of the Orissa Sales Tax Act, 1947 was treated as an independent time bar on assessment of tax due under the Act. An assessment made in revision under section 23(3) was regarded as a fresh assessment exercising the assessment power, so the limitation applied to revisional reassessment as well as original assessment. Orders made beyond that period were therefore barred by limitation. A dissenting view held that the proviso did not govern revisional orders, but the majority approach prevailed in sustaining the quashing of the delayed assessment orders. en-us Tue, 29 Oct 1963 00:00:00 +0530 Fri, 02 Jan 2015 16:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=99716 The thirty-six month limitation in the second proviso to section 12(6) of the Orissa Sales Tax Act, 1947 was treated as an independent time bar on assessment of tax due under the Act. An assessment made in revision under section 23(3) was regarded as a fresh assessment exercising the assessment power, so the limitation applied to revisional reassessment as well as original assessment. Orders made beyond that period were therefore barred by limitation. A dissenting view held that the proviso did not govern revisional orders, but the majority approach prevailed in sustaining the quashing of the delayed assessment orders. Case-Laws VAT and Sales Tax Tue, 29 Oct 1963 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=99716