(1.) The challenge in this writ petition is to a pre-revision notice dated 21.5.2004 issued by the respondent herein on the ground that as per Section 16(1)(a) of the Tamil Nadu General Sales Tax Act, 1959, a re-assessment has to be effected within five years.
(2.) Section 16(1)(a) of the said Act reads as under :
(3.) In this writ petition, the assessment in question is of the year 1998-99. The last date for issuing such a pre-revision notice was 31.3.2004, since the assessment was relating to the period 1998-99. Admittedly, the pre-revision notice was issued by the respondent vide proceedings dated 21.5.2004, after the expiry of five years of period prescribed under the said Act.