https://www.taxtmi.com/caselaws?id=166421 A proviso prescribing a limitation period for fresh assessment under the Bombay Sales Tax Act was construed by reading section 33 as a whole. Its placement below section 33(4A) was held to be a drafting feature only and not a restriction confining it to assessments under that sub-section or to cases where all returns were filed in time. Because the proviso did not itself refer to timely or belated returns, it was applied to any fresh assessment made to give effect to an earlier finding, direction, or order. The limitation therefore governed post-remand fresh assessments generally, including the thirty-six-month period. en-us Thu, 12 Aug 2010 00:00:00 +0530 Mon, 29 Sep 2014 08:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=166421 A proviso prescribing a limitation period for fresh assessment under the Bombay Sales Tax Act was construed by reading section 33 as a whole. Its placement below section 33(4A) was held to be a drafting feature only and not a restriction confining it to assessments under that sub-section or to cases where all returns were filed in time. Because the proviso did not itself refer to timely or belated returns, it was applied to any fresh assessment made to give effect to an earlier finding, direction, or order. The limitation therefore governed post-remand fresh assessments generally, including the thirty-six-month period. Case-Laws VAT and Sales Tax Thu, 12 Aug 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=166421