Petitioner was a dealer under the Kerala Value Added Tax Act (the Act) on the rolls of the third respondent, presently migrated to the Goods and Services Tax regime. On 17.11.2017, the third respondent issued Ext.P1 notice to the petitioner for assessing the escaped turnover of the petitioner for the year 2011-'12. Ext.P2 is the reply sent by the petitioner to Ext.P1 notice. In Ext.P2 reply, among others, the petitioner contended that the proceedings is barred by limitation. The third respondent assessed the escaped turnover of the petitioner as proposed in Ext.P1 notice, ignoring the plea of limitation raised by the petitioner. Ext.P3 is the order passed by the third respondent in this connection. Ext.P3 order is though appealable under Section 55 of the Act, the petitioner challenges the same in this proceedings on the ground that the same is an order issued without jurisdiction.

2. Heard the learned counsel for the petitioner as also the learned Government Pleader.

3. The learned counsel for the petitioner explicated the case set up by the petitioner pointing out that in terms of sub-section (1) of Section 25 of the Act, the proceedings for assessment of the escaped turn