J U D G M E N T

These batch of cases concern a common issue and hence heard and decided together. The issue projected by the petitioners is regarding the period of limitation for invoking Section 25(1) or 25A of the Kerala Value Added Tax Act, 2003 (hereinafter referred as the Act), power exrecised by the Deputy Commissioner under section 25B of the Act to extend the time for completing the assessment beyond the period specified under Section 25(1) and whether penalty proceedings could be taken against an assessee beyond the period specified under section 67(1) read with section 25(1) of the Act, or under section 45A read with section 19(1) of the Kerala General Sales Tax Act, 1963 (hereinafter referred as the KGST Act).

2. The cases on hand can be categorised under different groups for an easy analysis of the facts and disputed questions.

GROUP-A. These are cases wherein the contention urged is that the notice for assessment or assessment orders passed under section 25(1) are barred by limitation.

(1) In W.P.(C) No.10979/2014, Ext.P6 is the assessment order dated 28.3.2014, which is rectified as per Ext.P6A order. The notice under section 25(1) is issued on 28/3/2014 in respect of as