2020 (8) TMI 76

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..... The stand of the learned Special Government Pleader is that since the surprise inspection took place in the year 2016, this Court ought not to compute the limitation period from 30.06.2012. I am not able to agree. Even according to the respondent, the inspection took place in the year 2015; nothing stopped the respondent from taking action for assessing the escaped turnover immediately thereafter. .....

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..... h the respondent. The case on hand pertains to the assessment order 2010-2011. The petitioner is deemed to have been assessed as on 30.06.2012. The stand of the respondent is that the surprise inspection held in the business premises of the petitioner revealed certain suppressions. Therefore, alleging that there was an escaped turnover, the respondent proceeded to issue notice on 28.08.2018 and af .....

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..... hout going into that aspect, even if I assume that six years is the limitation period, still it is seen that the pre-revision notice was issued only on 28.08.2018. The cut off date in this case was 30th June 2012. The six year period expired on 30.06.2018. The notice under Section 27 (1) (a) of the Act came to be issued only after the expiry of the limitation period. 3. The stand of the learned .....

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