https://www.taxtmi.com/caselaws?id=148517 A taxing statute that treats each prescribed quarterly return-period as a separate unit of assessment does not permit one consolidated assessment order covering several periods. A notice may refer to multiple defaulted periods, but it cannot confer power to merge distinct assessment periods. Estoppel could not cure the defect, because there is no estoppel against statute and an ultra vires assessment remains a nullity. On limitation, the demand under section 11(2a) was tested by reference to the assessee's accounting year, and the notice was within time; recovery proceedings were not required to conclude within that same period. en-us Fri, 02 May 1969 00:00:00 +0530 Mon, 29 Apr 2013 14:37:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=148517 A taxing statute that treats each prescribed quarterly return-period as a separate unit of assessment does not permit one consolidated assessment order covering several periods. A notice may refer to multiple defaulted periods, but it cannot confer power to merge distinct assessment periods. Estoppel could not cure the defect, because there is no estoppel against statute and an ultra vires assessment remains a nullity. On limitation, the demand under section 11(2a) was tested by reference to the assessee's accounting year, and the notice was within time; recovery proceedings were not required to conclude within that same period. Case-Laws VAT and Sales Tax Fri, 02 May 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=148517