2023 (12) TMI 164

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....ali For the Respondent : Ms.Amrita Dinakaran, Government Advocate ORDER The short question that arises for consideration is whether the impugned notice dated 13.12.2019 issued for the assessment year 2007-2008 under the TNVAT Act is barred by limitation. 2. It is submitted by the learned counsel for the petitioner that in view of the deeming contained in Section 22(2) of the Act, the a....

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....der TNVAT Act inasmuch as the input tax credit entitlement will have to be made on the basis of declaration form filed under the CST Act. It was submitted that the assessment order under the CST Act was originally passed on 23.12.2015 against which an appeal was preferred in A.P.C.No.28/2016 dated 15.03.2018 and consequential order giving effect to the Appellate Authority's order was also made....

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....06.2012 and thus any proceeding under Section 27 of the Act must be initiated within six years thereof i.e.,30.06.2018. 6. The impugned proceedings under Section 27 is initiated only on 30.12.2018 thus barred by limitation. An order barred by limitation is a nullity and lacking jurisdiction. In this regard, it may be useful to refer to the judgment of the Hon'ble Supreme Court in the case o....