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TMI Blog2018 (1) TMI 1627X X X X Extracts X X X X X X X X Extracts X X X X ..... on 09.06.2016. Therefore, the assessment for the relevant year could not have been reopened and redone. The respondent cannot place reliance on the amendment to Section 27 of the TNVAT Act, which was brought about by Act 23 of 2012, with effect from 19.06.2012, and therefore, such amendment can be only on prospective. Hence, the respondent cannot state that the period of limitation is six years. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er, on the file of the respondent, under the provisions of the Tamil Nadu Value Added Tax Act, 2006 (TNVAT Act) has filed this Writ Petition, challenging the assessment order, dated 23.05.2017, passed under the provisions of the TNVAT Act for the assessment year 2008-09. 3. The impugned assessment order is a revision of assessment, which was done, pursuant to the returns filed by the petitioner ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and the time limit of five years expires on 09.06.2016. However, the amendment brought under Act 23/2012 amending Section 27 of the TNVAT Act with effect from 19.06.2012 has held to be prospective. Therefore, the six years limitation period cannot be made applicable to the petitioner's case. In this regard, the learned counsel placed reliance on the decision in the case of Universal Abrasives ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act, which was brought about by Act 23 of 2012, with effect from 19.06.2012, and therefore, such amendment can be only on prospective. Hence, the respondent cannot state that the period of limitation is six years. This very issue was decided by the Court, in the case of Universal Abrasives Vs. Commercial Tax Officer, Manali Assessment Circle, Chennai, reported in [(2014) 68 VST 386 (Mad)], which ..... X X X X Extracts X X X X X X X X Extracts X X X X
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