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TMI Blog2020 (3) TMI 1456X X X X Extracts X X X X X X X X Extracts X X X X ..... e beyond the period of three years or not - Section 24(5) of the Pondicherry Value Added Tax Act - HELD THAT:- The writ petitions filed by the petitioner are premature and have been rightly dismissed by the learned Single Judge. The objections with regard to the limitation and other objections, if any, were required to be filed before the learned assessing authority himself and in that event, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Co., has filed these intra court appeals aggrieved by the order dated 12.11.2019, passed by the learned Single Judge, dismissing the Writ Petitions, which according to the learned Single Judge, were directed only against the summons/preassessment notices dated 28.5.2018, pertaining to the years 2011-12, 2012- 13, 2013-14 and 2014-15 and therefore with a liberty to the petitioner to raise all his ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... efore the expiry of three years, this Court is of the view that the consequent preassessment notices impugned in these writ petitions are not barred by limitation and therefore, section 24(5) is not attracted in these cases in any manner. Needless to state that it is for the petitioner to participate in the assessment process by filing their objection to the notice of proposal and raise all the co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Court that as per Section 24(5) of the Pondicherry Value Added Tax Act, no assessment could be made beyond the period of three years and therefore the summons/pre-assessment notice is bad in law and deserves to be interfered with by the writ court. 4. Having heard the learned counsel for the appellant, we are satisfied that the writ petitions filed by the petitioner are premature and have been ..... X X X X Extracts X X X X X X X X Extracts X X X X
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