https://www.taxtmi.com/caselaws?id=343187 A tax proceeding described as rectification was treated according to its substance, not its label, so limitation under the prescribed five-year period applied rather than a later reopening. The Madras High Court noted that the assessment record already disclosed and accepted the snack purchases, while the revision notice incorrectly proceeded as if no purchase details had been produced. Because the action was founded on a demonstrably wrong factual premise and showed non-application of mind, the impugned order was considered unsustainable on merits as well as time-barred. en-us Fri, 17 Mar 2017 00:00:00 +0530 Sat, 20 May 2017 09:05:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343187 A tax proceeding described as rectification was treated according to its substance, not its label, so limitation under the prescribed five-year period applied rather than a later reopening. The Madras High Court noted that the assessment record already disclosed and accepted the snack purchases, while the revision notice incorrectly proceeded as if no purchase details had been produced. Because the action was founded on a demonstrably wrong factual premise and showed non-application of mind, the impugned order was considered unsustainable on merits as well as time-barred. Case-Laws VAT and Sales Tax Fri, 17 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343187