https://www.taxtmi.com/caselaws?id=127756 A notice initiating reassessment under section 11(2) of the Central Provinces and Berar Sales Tax Act was treated as the real commencement of fresh proceedings, so it had to be issued within the statute's three-year limit for escaped assessment; issuing it later was barred. By contrast, an assessment under section 11(1) on a duly filed return and tax already paid was only a formal acceptance of the declared liability, created no fresh liability, and was not subject to any implied three-year limitation because the provision contained none. The text therefore distinguishes reassessment-type action from formal assessment and applies limitation only where the statute expressly or necessarily requires it. en-us Wed, 23 Jul 1958 00:00:00 +0530 Sat, 16 Mar 2013 10:19:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=127756 A notice initiating reassessment under section 11(2) of the Central Provinces and Berar Sales Tax Act was treated as the real commencement of fresh proceedings, so it had to be issued within the statute's three-year limit for escaped assessment; issuing it later was barred. By contrast, an assessment under section 11(1) on a duly filed return and tax already paid was only a formal acceptance of the declared liability, created no fresh liability, and was not subject to any implied three-year limitation because the provision contained none. The text therefore distinguishes reassessment-type action from formal assessment and applies limitation only where the statute expressly or necessarily requires it. Case-Laws VAT and Sales Tax Wed, 23 Jul 1958 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=127756