https://www.taxtmi.com/caselaws?id=127734 The phrase "three calendar years" in section 11(5) of the C.P. and Berar Sales Tax Act, 1947 was given its ordinary meaning of a year running from 1 January to 31 December, not a 36-month period from expiry of the assessment year; on that basis, the notice and assessment proceedings were within time. The retrospective amendment could validate the assessment by removing the limitation bar in fiscal matters, but it did not sustain a penalty where the proviso to the amending Act barred penalties that could not lawfully have been imposed when proceedings began. The assessment survived, while the penalty was quashed. en-us Fri, 28 Feb 1958 00:00:00 +0530 Fri, 15 Mar 2013 10:52:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=127734 The phrase "three calendar years" in section 11(5) of the C.P. and Berar Sales Tax Act, 1947 was given its ordinary meaning of a year running from 1 January to 31 December, not a 36-month period from expiry of the assessment year; on that basis, the notice and assessment proceedings were within time. The retrospective amendment could validate the assessment by removing the limitation bar in fiscal matters, but it did not sustain a penalty where the proviso to the amending Act barred penalties that could not lawfully have been imposed when proceedings began. The assessment survived, while the penalty was quashed. Case-Laws VAT and Sales Tax Fri, 28 Feb 1958 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=127734