CHAGLA, C.J. - An interesting and important question with regard to the question of limitation under the Central Provinces and Berar Sales Tax Act, 1947, arises in this Full Bench. The facts giving rise to this Full Bench are these. The petitioner is a registered dealer and his chargeable accounting year is from the 1st July to the 30th June. He made his return and paid the tax which according to him was due for the years 1st July, 1951, to 30th June, 1952, 1st July, 1952, to 30th June, 1953, and 1st July, 1953, to 30th June, 1954. On the 31st December, 1956, the Commissioner of Sales Tax issued a notice under section 11(2). This notices was served upon the assessee with regard to the first year on the 4th January, 1957, and with regard to the second year on the 8th January, 1957. The contention of the assessee was that his notice was bad because it was served three years after the end of the chargeable accounting year, and this petition was field in this Court challenging the notice and for an order preventing the Commissioner to act upon the notice.

In order to understand the question that we have to decide, it is necessary to look at the scheme of the Sales Tax Act. The