A.K. Goel, C.J.

1. This order will dispose of W.P. (C) No. 3322 of 2010, W.P. (C) No. 3327 of 2010 and W.P. (C) No. 3267 of 2010 as it is stated that the issue involved is identical, i.e., whether the impugned reassessment orders are barred by limitation prescribed under section 19(2) of the Assam General Sales Tax Act, 1993. All the three writ petitions have been filed by the same assessee for three different assessment years. Proceedings for reassessments were initiated vide notice dated September 6, 2000 under section 18 of the Act and, thereafter, reassessment was completed on January 2, 2010/March 31, 2010, which is beyond the period of three years, stipulated under section 19(2) of the Act, and on that ground the same is sought to be quashed. We have heard learned counsel for the parties.

2. Since reassessment proceedings are patently hit by section 19(2) of the Act, we have called upon learned counsel for the Revenue to justify the same. His submission is that the period prescribed is not for passing the order of reassessment but for initiating reassessment proceedings or for completing the said proceedings without passing final order. He has placed reliance on the judgme