Order Radha Mohan Prasad, J. Both the writ application, which relate to different assessment years involving similar facts and law have been heard analogous and as such, they are being disposed of by this common judgment. 2. The case of the petitioner in both the writ application is that for the first time notice bearing no. 468 dated 3.5.88 for assessment under section 27 of the Bihar Agriculture Produce Market Act, 1960 (herein after referred to as the Act') was issued by the Secretary of the Agriculture Produce Market Committee, Chanpatia in form 27 Ga. inviting objection. In response to the said notice the representative of the petitioner company produced all books of account on the date fixed and on 2.8.88 the Respondent special officer passed order of assessment for the period 1979-80, 80-81 and 81-82 Photo state copies of which are annexed to this writ• petition as Annexure 6' in C.W.J.C. no. 4588 (hereinafter referred to as the first case )and as Annexure 6 and 6/A in C.W.J.C. no. 9103/92 (hereinafter referred to as the second case). 3. The petitioner fired appeal against the said order of assessment of market fee on the purchase of sugar cane by it during the period aforementioned before the Regional Director, Muzaffarpur, who by his order dated 25.7.89 set aside the order of assessment and directed the respondent Market Committee to pass a fresh order in the light of section 27 A of the Act as also in regard to the penalty he directed for passing of a fresh order after full consideration. 4. Thereafter, it appears that the Assessment sub-Committee of the Market committee passed fresh order of assessment on 28.12.1990. The petitioner company again filed appeal before the same appellate authority, who finally dismissed it on 24.10.91 along with other appeals preferred for the subsequent periods including 1980-81 and 81-82. This time, however, penalty was reduced from 100% to 15% of assessed Market fee. The said appeals were dismissed on the sole ground that in view of section 27B/(2) of the Act one third of the total fee assessed had not been deposited The petitioner company preferred revision before the Managing. This time, however, penalty was reduced from 100% to 15% of assessed Market fee. The said appeals were dismissed on the sole ground that in view of section 27B/(2) of the Act one third of the total fee assessed had not been deposited The petitioner company preferred revision before the Managing. Director against the aforesaid order, who by his order dated 5.2.92 rejected the contention of the petitioner and held that as condition of section 27B (2) had not been compiled with by the petitioner;' the appeal proceedings before the Regional Director, Muzaffarpur against the assessment order on the purchase of sugar cane for the periods mentioned above -as also the order dated 24.10.91 passed therein by the Regional director / being violative of the scheme of the Act were quashed with further direction that as a consequence, the order of the assessment passed by the A.P.M.C. Chanpatia, should be deemed to be uninterferred. A true copy of the same has been annexed as Annexure 8. The petitioner prays for quashing of assessment order, the appellate order as also the Revisional order contained in Annexures 6, 7 and 8 respectively. 5. A counter affidavit has been filed on behalf of the Managing Director of the Board, the Market committee. Chanpatia and the Secretary of the said Market Committee, in which it is stated inter ass that the petitioner is liable to pay market fee on purchase of sugar can as will as on sugar molases and other agricultural produce mentioned in the schedule of the Act in which the petitioner deals. Further, it is stated that as per the account of the Market Committee, the petitioner has not paid any market fee on produce of sugar cane for the aforementioned periods. In paragraph 8 of the said counter affidavit it has been stated that much prior to the aforementioned notice dated 3.5.88 the petitioner was issued notice inform 'C' vide letter no. 93 dated 24.1.87 by the respondent Market Committee in respect of determination of fee for the financial year 1979-80 and was asked to produce his books of account on 30.1.87 by the respondent which the petitioner failed to comply. It has been stated in the counter affidavit that the petitioner company failed to comply. 93 dated 24.1.87 by the respondent Market Committee in respect of determination of fee for the financial year 1979-80 and was asked to produce his books of account on 30.1.87 by the respondent which the petitioner failed to comply. It has been stated in the counter affidavit that the petitioner company failed to comply. It has been stated in the counter affidavit that the petitioner company failed to comply with the direction of the appellate authority despite several notices to it for producing its book of account and as such, the Assessment Sub Committee made assessment, taking lenient view and reducing the amount of penalty from 100% to merely 15%. 6. Mr. Agrawal, learned Counsel appearing for the petitioner has raised a short question that the aforementioned notices, the assessment proceedings and order passed therein including the revisional order are wholly without jurisdiction as the very notices impugned are barred by limitation prescribed under section 27AA of the Act. Thus, according to the learned Counsel this application must succeed on the simple question of limitation in starting a proceeding under the said provision which expired long before. Section 27AA(a), of the Act provides for assessment of the fee by the sub-Committee if upon information received it is satisfied that reasonable ground exists to believe that assessment of market fee for any period on the amount of purchase or sale by the trader has escaped under section 27Ka or there has been wrong deduction made, then the Fee assessment sub-Committee before expiry of six years of the end of that trader has concealed committed or has failed to disclose fully particulars or has furnished incorrect particulars of such trade and thereby furnish return, showing figures below the real amount and under clause (b)-in any other case within four year of the completion of the period the fee Assessment sub-Committee shall serve notice upon, the trader in form Ka , in which the details of the information to be included shall be given and thereafter for assessment or reassessment of the amount of fee in respect of the purchase and sale made by such traders. The said provision, which is only available in Hindi is being reproduced hereunder: 7. In the present writ applicant it can be seen that the period of assessment involved are of 1979-80, 80-81 and 81-82 and the proceeding was initiated by the notice dated 3.1.1988. The said provision, which is only available in Hindi is being reproduced hereunder: 7. In the present writ applicant it can be seen that the period of assessment involved are of 1979-80, 80-81 and 81-82 and the proceeding was initiated by the notice dated 3.1.1988. Contained in Annexure 5 to the writ application although in the counter affidavit filled in the first writ application it is claimed that notice for the period 79-80 was issued for the first time on 24.1.1987 and in support there of a photo copy of the same has been annexed as Annexure B but in my opinion, that is of no avail in support of the case of the respondents to sustain the impugned proceeding and orders passed therein. 8. It will be seen that the proceeding in any case in respect of the aforementioned period of assessment were beyond period on six years, which is the maximum period of limitation provided for taking action under section 27AA. Thus, I find substance in the submission of the learned counsel for the petitioner that the impugned notice, assessment proceeding and the orders passed in connection there of were barred by limitation prescribed under section 27AA of the Act. 9. However, Mr. Bajla, learned Counsel appearing for the Market Board and Market Committee Submitted that liability to pay cannot stand obliterated merely because of the limitation prescribed under section 27AA of the Act. The learned Counsel further submitted that in this in this view of the matter this provision being machinery section and not the charging provision, interpretation should be given to effectuate the very purpose of the Act and not to defeat the same, Section 27 of the Act is really the charging section providing for is really the charging section Providing for power to levy fee, Part VI of the Bihar Agriculture Produce Market Rules 1976 provides for the manner and procedure for levy of fee and its collection. Rule 82 (2) of the said part provides that if the buyer is a license he shall within a week of the purchase, deposit the market fee with the market committee. Rule 82 (2) of the said part provides that if the buyer is a license he shall within a week of the purchase, deposit the market fee with the market committee. It is not in dispute that the petitioner is company incorporated under Indian Companies Act having its factory at Chanpatia in the district of West Champaran with its registered office at Kanpur in the State of Uttar Pradesh, It is also true that the petitioner is engaged in the business of manufacturing sugar from sugar cane purchased from areas specified specifically reserved or allotted to it by the State Government. Further, it cannot be disputed that the petitioner is a licensee and buyer of sugar cane. 10. According to the learned Counsel for the petitioner, the present impugned notice will be covered by clause (b) of section 27AA which provides for only four years limitation but in any case even if it is taken to be covered by clause (a) of the said section which provides for six years limitation of the proceeding for initiation of the proceeding for assessment under section 27AA the case of the petitioner Joes beyond its so far as in respondent the aforementioned assessment years are concerned. By this provision it is manifest that the legislature intended the Market Committee or Board to be very much vigilant and to net all such persons who also were liable to file return had omitted to do so during the period in question was out, inasmuch as under sub section (2) of section 27A every licences is required to file his reture in form Ka, in respect of his business for every trade in respect of purchase or sale within 15 days of the month to the secret art of the Market Committee or to any officer authorised by the Board. Under the provision contained in section 27AA the period is enlarged to net all such persons who do not file return within time provided the condition precedent contemplated in that section were available in any given case. 11. In my opinion, therefore, this view cannot be said to be involving any interpretation based upon any rule of construction of the relevant provisions and the conclusion is inevitable. The supreme Court in the case of Gurusahai Saigal Vs. 11. In my opinion, therefore, this view cannot be said to be involving any interpretation based upon any rule of construction of the relevant provisions and the conclusion is inevitable. The supreme Court in the case of Gurusahai Saigal Vs. The Commissioner of Income tax ( AIR 1963 S.C. 1062 ) observed as follows : 'Now it is well recognised that the rule of construction on which the assessee relies applies only to a taxing provisions in a taxing statute. It does not, for example, apply to a provision not creating a charge for the tax but laying down the machinery for its calculation or procedure for its collection. The provisions in a taxing statute dealing with machinery for assessment have to be construed by the ordinary rules of construction that is to say in accordance with the clear intention of the legislature which is to make a charge levied affective." 12. In the instant case I do not consider it necessary nor I am called upon to give any meaning of law by giving my own construction. In my opinion, .the scheme of the Act itself is unambiguous and clear. Thus, the principle laid down in the aforesaid decision of the Supreme Court has no application to the facts of the cases in hand. 13. As regards the submission of Mr. Bajla, learned Council appearing for the respondent that the liability to pay cannot stand obliterated only because of limitation prescribed under section 27AA of the Act I am unable to accept the same. If the said submission of the learned Counsel appearing for the respondents is accepted, then it shall make the provisions contained under section 27AA redundant, which against the well known rule of interpretation of the statute. It is well settled that every provision of statute has to be given full effect and that the court should not place that construction which will make the provision redundant or to overlap other provision or to limit its application unless that is the only reasonable construction. The supreme Court in the case of Ghanshyamdas Vs. Regional Asst. It is well settled that every provision of statute has to be given full effect and that the court should not place that construction which will make the provision redundant or to overlap other provision or to limit its application unless that is the only reasonable construction. The supreme Court in the case of Ghanshyamdas Vs. Regional Asst. Commissioner, Sales Tax ( AIR 1964 SC 766 ) dealing with taxing statute, held that construction attributing redundancy to legislature shall not be accepted except for compelling reason while laying down the cardinal rule of construction the Supreme Court in the case of Dinesh Chandra Sangma V s. State of Assam (A.I.R. 1978 S.C. 17) held that no words should be considered redundant or surplus in interpreting provision of statute or rule. 14. In the instant case the respondents have not come up with any compelling reasons which can have any impact to deviate from the cardinal rule and accept the aforementioned submission of Mr. Bajla. 15. A division Bench of this Court in case of Hazari Sah V s. Agricultural Income Tax Officer (1977 PLJR 361) in similar situation, though dealing with the provision of the Bihar Agricultural income tax Act 1948 where there was a provision similar to section 27AA of the Act prescribing limitation, held that the proceeding taken by respondent no.1 being beyond the prescribed period of limitation must be held to be invalid in the said case also the proceeding was initiated beyond the period of six years which was largest period of limitation provided for initiation thereof from the end of the agriculture year and the Court held the proceeding to be invalid. 16. From facts of the present cases it would appear that the period of assessment involved in the first writ it application is from 1.4.79 to 31.3.80 and in the second case from 1.4.80 to 31.3.82. Thus, in view of the aforementioned provisions, as contained in section 27AA of the Act, the proceeding can only be started before the expiry of six years from the end of that year i.e. 31.3.1980 in the first case and 31.3.82 in the second case. 17. Thus, even assuming that both the cases are covered by clause (a) of Section 27AA, then in that case in the first case the proceeding could have been initiated before 31.3.1986 and in the second case before 31.3.1987 and 31.1.1988. 17. Thus, even assuming that both the cases are covered by clause (a) of Section 27AA, then in that case in the first case the proceeding could have been initiated before 31.3.1986 and in the second case before 31.3.1987 and 31.1.1988. But even for argument sake the statement made in the counter affidavit filed in the first case is taken to be correct, wherein it is stated that the notice was issued on 24.1.87 yet the proceeding will barred by limitation. So far as the periods of assessment involved, in the second case are concerned, it is not in dispute that notice were issued for the first time on 3.5.1988, i.e. beyond the statutory, period prescribed under section 27AA. Accordingly, I hold that the notices, proceedings and the orders passed there under are not sustainable. 18. In the result, the writ applications have to succeed on the simple ground that the proceedings taken with respect to the periods aforementioned were barred by limitation. Accordingly the orders of assessment impugned in these application including the subsequent passed in appeal and revision' are hereby quashed. However in the facts and circumstances of the cases, there shall be no order as to costs. Applications allowed.