judgment

S.B. Sinha, J. —

1.Leave granted.

2.What should be the reasonable period for reopening an order of assessment under the Punjab General Sales Tax Act is the question involved in this appeal which arises out of a judgment and order dated 22.12.2006 passed by a Division Bench of the High Court of Punjab and Haryana at Chandigarh in CWP No.15477 of 2006 whereby and whereunder the writ petition filed against a notice dated 4.9.2006 issued by Revisional Authority-cum-Assistant Excise and Taxation Commissioner, Bhatinda to the respondent was allowed.

3.Before embarking upon the said question, we may notice the basic fact of the matter.

4.Respondent herein is a federation of milk union. It is a cooperative society registered under the Punjab Cooperative Societies Act, 1948. It is also registered as a dealer under the Punjab General Sales Tax Act and the Rules framed thereunder. It has been running milk plants under the control of Punjab State Cooperative Milk Producers Federation Limited, Chandigarh. The Act provides for levy of purchase tax on milk when purchased for use in the manufacture of goods which are specified in Schedule C thereof. Milk when purchased for use in the manufac