In Brief
This case involves eight consolidated civil appeals concerning the interpretation of the power to extend the assessment period under the Punjab General Sales Tax Act, 1948. The issue is whether the Commissioner can grant time extensions to the Assessing Officer after the normal three-year assessment period has expired. The Supreme Court held that the power to extend must be exercised before the limitation period expires. Once that period lapses, the assessee acquires immunity from assessment and the Revenue loses the right to assess. The Court rejected contentions based on the Code of Civil Procedure and Income Tax Act as inapplicable, and dismissed all appeals, upholding the High Court's decision that late extension orders are invalid.
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