Limitation for consequential tax orders can abate assessment and nullify penalty when no valid order is passed.

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....Failure to pass a consequential order within the statutory limitation caused the assessment to abate because the order giving effect to the appellate decision was a quasi-judicial recomputation of tax liability, not a mere administrative formality. The appellate order had changed the basis of taxation and required verification and hearing, so the Assessing Officer had to act within the prescribed period; once that period expired, no further demand could be enforced and the return stood accepted as filed. As the penalty proceedings depended on the original assessment basis, the disappearance of that foundation rendered the penalty order and demand notice unsustainable, with refund of any recovered amount and applicable interest.....