Hon'ble LODHA, J.—This revision petition under Section 7 of the Rajasthan Tax on Entry of Motor Vehicles into Local Areas Act, 1988 ('the Act of 1988') read with Section 84 of the Rajasthan Value Added Tax Act, 2003 is directed against order dated 24.6.10 passed by the Rajasthan Tax Board, Ajmer, whereby the appeal preferred by the Assessing Authority against the order dated 3.10.07 of the Deputy Commissioner (Appeals), setting aside the assessment order dated 13.2.07, stands dismissed. 2. The relevant facts in nutshell are that the respondent purchased a motor vehicle from M/s. Patwa Abhikaran, Nimach, (M.P.) vide sale invoice No. 318 dated 29.11.04, entry whereof was effected into local area of State of Rajasthan. The vehicle was got registered in the State of Rajasthan with the concerned Registering Authority on 21.12.04. As per provisions of Section 3 of the Act of 1988, the tax is leviable on the motor vehicle brought within the local area of State of Rajasthan and liable to be registered therein at the rate notified by the State Government. However, the respondent neither produced the Form ET1 alongwith the purchase bill at the entry check post in conformity with the provision contained in Rule 4 of the Rajasthan Tax on Entry of Motor Vehicles into Local Areas Rules, 1992 ("the Rules") nor deposited the tax with the authority concerned and, therefore, the Assessing Authority issued a notice dated 23.11.06, directing the respondent to produce the purchase bill so as to assess the liability of tax on the purchase value of the motor vehicle in conformity with the provisions of Section 3 of the Act of 1988 and penalty in terms of provisions of Section 6 of the Act of 1988. 3. The respondent filed a reply to the notice contending that the amount of tax leviable on purchase value of the motor vehicle entry whereof has been effected within the local area is equivalent to the amount to the tax already paid by him under the law relating to General Sales Tax in force in the State of Madhya Pradesh and thus by virtue of provisions of Section 4(2) of the Act of 1988, he is entitled for adjustment and, therefore, no tax is payable. That apart, the respondent contended that after expiry of period of 2 years from the date of transaction of sale, the proceedings initiated by the Assessing Authority for assessment of tax under the Act of 1988 is barred by limitation. 4. After due consideration of submissions of the assessee made as aforesaid, the Assessing Authority opined that since the respondent has not produced the Form-ET1 in terms of provisions of Rule 3 of the Rules, therefore, he is not entitled for reduction in the tax liability as claimed in terms of provisions of Section 4(2) of the Act of 1988. Regarding the assessment proceedings being barred by the limitation, the Assessing Authority observed that since the entry of vehicle was effected into local area on 21.12.04 and the proceedings for assessment of tax against the respondent were initiated prior to it, therefore, the assessment proceedings cannot be treated to be barred by limitation. The Assessing Authority assessed the liability of tax, interest and penalty vide assessment order dated 13.2.07 and created a demand for Rs. 55,617/- against the respondent. 5. Aggrieved by the assessment order dated 13.2.07, the respondent preferred an appeal before the Deputy Commissioner (Appeals), Commercial Taxes, Udaipur. The Appellate Authority arrived at the finding that the assessment of the respondent has to be made treating him to be a casual trader in terms of provisions of Section 2(ccc) of the Rajasthan Sales Tax Act, 1954 ('RST Act 1954') and, therefore, by virtue of provisions of Section 10A & 10B (1)(3) of the RST Act 1954, the assessment order was required to be passed within a period of two years from the date of transaction of sale i.e. 29.11.04 and, therefore, the assessment order passed after 29.11.06 is barred by limitation. Accordingly, vide order dated 3.10.07, the Appellate Authority proceeded to set aside the assessment order passed by the Assessing Authority. 6. Aggrieved by the appellate order, the Assessing Authority preferred an appeal before the Rajasthan Tax Board, Ajmer which stands dismissed by the order impugned in this revision petition. Accordingly, vide order dated 3.10.07, the Appellate Authority proceeded to set aside the assessment order passed by the Assessing Authority. 6. Aggrieved by the appellate order, the Assessing Authority preferred an appeal before the Rajasthan Tax Board, Ajmer which stands dismissed by the order impugned in this revision petition. The Tax Board opined that the assessment of tax on the entry of motor vehicle effected by the respondent into the local area was required to be made in accordance with the procedure laid down for assessment in case of a casual trader under the provisions of Rajasthan Sales Tax Act, 1994 ('RST Act 1994') and since, the assessment has not been made within a period of two years from the date of transaction of sale as prescribed, the assessment order passed by the Assessing Authority is indisputably barred by limitation. Hence, this revision petition. 7. Learned counsel for the petitioner submitted that the motor vehicle in question was purchased by the respondent on 29.11.04, however, the same was registered in the State of Rajasthan on 21.12.04 and since, the Assessing Authority had initiated the assessment proceedings prior to 21.12.06, therefore, the assessment made cannot be said to be barred by limitation. Learned counsel submitted that as per the provisions of Section 3 of the Act of 1988, any person who imports vehicle into local area and is not covered by the provisions of Section 3(2)(a) of the Act of 1988, would be assessed as casual trader and provision of the RST Act, 1994 shall apply mutatis mutandis to it. Accordingly, it is submitted by the learned counsel that as per provisions of Section 31(3) of the RST Act 1994, the Assessing Authority was empowered to assess the tax due to best of his judgment and direct the casual trader to pay the tax amount within such time and in such manner as it may direct. Learned counsel submitted that the Section 31(5) of the Act of 1988 specifically provides that no order under Section, 31(3) shall be passed after expiry of period of two years from the date of completion of transaction; it nowhere provides that the assessment order must be passed within a period of two years and therefore, the question of computing the limitation of two years for passing the assessment order shall not commence from the date of transaction of sale i.e. 29.11.04. Accordingly, it is submitted that the assessment order passed by the Assessing Authority is well within limitation and the order impugned passed by the Tax Board affirming the order passed by the Deputy Commissioner (Appeals) deserves to be set aside. 8. I have considered the submissions of the learned counsel for the petitioner and perused the relevant statutory provisions. 9. Indisputably, under Section 3 of the Act of 1988, the tax is payable by the importer on the purchase value of the motor vehicle entry of which is effected into local area from any place outside the State of Rajasthan, at the rate as notified by the State Government from time to time. As per Section 3(2)(a) if the importer is a dealer registered or liable to be registered under the provisions of RST Act, 1954 (later substituted by 'RST Act 1994') the tax shall be payable in the manner and within time tax on sales is payable by him under the said Act, whereas, as per Section 3(2)(b) a person not covered by clause (a) on the date of entry of motor vehicle into local area, tax shall be paid to the incharge of entry check post or the commercial taxes officer of the area where he ordinarily resides or carries on any business or provides any service and the provisions of RST Act, 1954 as applicable to a registered dealer or casual trader shall mutatis mutandis apply to such dealer as the case may be, such person. Besides, by virtue of Section 7 of the Act of 1988, subject to the provisions of the Act of 1988 and the Rules made thereunder the provisions with regard to the assessment, reassessment, collection and enforcement of payment of tax under the Act of 1954 have been made applicable to the proceedings under the Act of 1988. Thus, the assessment of tax leviable on the entry of motor vehicle in question for the respondent who is not covered by clause (a) of Section 3(2) was required to be made treating him to be a casual trader in accordance with the procedure laid down under the provisions of the RST Act 1994. 10. Thus, the assessment of tax leviable on the entry of motor vehicle in question for the respondent who is not covered by clause (a) of Section 3(2) was required to be made treating him to be a casual trader in accordance with the procedure laid down under the provisions of the RST Act 1994. 10. Indisputably, the assessment in the instant case shall be governed by the provisions of sub section (2) & (3) of Section 31 of the Act of 1994 which provides for procedure in case of a casual trader who is not registered. The provisions of Section 31 of the Act of 1994 may be beneficially quoted: 31. Assessment in case of a casual trader.-(1) A casual trader who is registered under the Act, shall be assessed like any other registered dealer. (2) A casual trader who is not registered shall, immediately on completion of a transaction of sale or purchase, for which he is liable to pay tax, report to the assessing authority having jurisdiction with reference to the place of such transaction or to the Incharge of the nearest check-post, the amount of sale or purchase price and the tax payable thereon and shall deposit the amount of tax with such assessing authority or Incharge of the check-post within such time and in such manner as such authority or Incharge may direct. (3) Where a casual trader fails to make a report as required by sub-section (2), the assessing authority having jurisdiction or the Incharge of the nearest check post may require such casual trader to make a report of the sale or purchase price and the tax due, failing which such assessing authority or Incharge of the check-post may assess to the best of its judgment the amount of tax due and direct the casual trader to pay the amount of tax within such time and in such manner as it may direct. (4) Where a casual trader fails to pay the tax as directed by the assessing authority or the Incharge of the check-post under sub-sections (2) and (3), the goods belonging to such casual trader shall be detained until the tax is paid or adequate security for payment of tax is furnished. (4) Where a casual trader fails to pay the tax as directed by the assessing authority or the Incharge of the check-post under sub-sections (2) and (3), the goods belonging to such casual trader shall be detained until the tax is paid or adequate security for payment of tax is furnished. (5) No order under sub-section (2) shall be passed after the expiry of one year from the date of making the report, and under sub-section (3) after the expiry of two years from the date of completion of the transaction. (6) The amount of tax payable by a casual trader under sub-section (2) or (3) shall be deemed to be a demand payable by a registered dealer and all the provisions of recovery under the Act shall apply accordingly to such demand. (7) The assessing authority may in writing authorise any official subordinate to it to perform all or any of its transaction to be performed under this section. (8) The assessing authority may, suo motu or on an application of the casual trader, filed within thirty days of the date of deposit or realisation of tax, review or revise any order passed or action taken by the subordinate official, authorised under sub-section (7).] 11. Admittedly, the respondent neither paid the tax nor reported the entry of motor vehicle into the local areas to the Assessing Authority concerned as per mandate of provision of sub-section 2 of Section 31 and, therefore, the Assessing Authority having jurisdiction directed the respondent to make a report of purchase price of the motor vehicle entry whereof was effected into local area, in exercise of the power conferred by sub-section (3) of Section 31 of the Act of 1994 and accordingly, after considering the reply to the notice filed on behalf of the respondent vide assessment order dated13.2.07 assessed the liability of tax, interest and penalty payable in respect of the transaction in question under the provisions of Act of 1988. 12. It is to be noticed that as per provisions of sub-section (5) of Section 31, no order under sub section (2) shall be passed after expiry of one year from the making of the report and under sub section (3) after expiry of two years from the date of completion of transaction. 12. It is to be noticed that as per provisions of sub-section (5) of Section 31, no order under sub section (2) shall be passed after expiry of one year from the making of the report and under sub section (3) after expiry of two years from the date of completion of transaction. Thus, the order impugned which has admittedly passed in exercise of the power conferred under sub section (3) of Section 31 was required to be passed within a period of two years from the date of completion of transaction. 13. The transaction of sale of the motor vehicle in question was completed on 29.11.04, therefore, strictly speaking as per the mandate of the provisions of sub-section (5) of Section 31, the assessment order could have been passed on or before 28.11.06 and, therefore, the assessment order passed on 13.2.07 is ex facie barred by limitation. But then, the incidence of tax in terms of provisions of Section 3 of the Act of 1988, is the entry of motor vehicle into local area for use or sale therein and which is liable for registration in the State under the Motor Vehicles Act, 1988 and, therefore, if the date of completion of transaction for the purpose of levy of tax is extended to the date of entry of motor vehicle into the local areas from outside the State, then also the assessment order passed by the Assessing Authority on 13.2.07, is barred by limitation inasmuch as the vehicle was brought within the local area obviously prior to 21.12.04 i.e. the date on which the vehicle was duly registered with the registering authority of the State of Rajasthan under the provisions of the Motor Vehicles Act, 1988. Thus, viewed from any angle, the assessment order 13.2.07 passed by the Assessing Authority is ex facie barred by limitation. 14. The contention of the learned counsel for the petitioner that sub section (5) of Section 31 does not refer to the 'assessment order' but it refers to only "order" and, therefore, the limitation provided for passing the assessment order within two years from the date of completion of transaction of sale cannot apply in the instant case, to say the least is absolutely misconceived. It is to be noticed that sub section (3) of Section 31 specifically provides for passing of best judgment assessment in case a casual trader who has failed to make a report as required by sub section (2) of Section 31 and thus the provisions of sub section (5) providing for limitation of two years for passing of the order from the date of completion of transaction refers to the assessment order and no other order. The provisions of Section 31 nowhere provides that the assessment proceedings in case of a casual trader not reporting the transaction shall be completed within a period of two years from the date of initiation of proceedings by the Assessing Authority in terms of provisions of Section 31(3) of the Act of 1994. Needless to say that this Court cannot read something in the provisions incorporated which is not there. 15. In view of the discussion above, in considered opinion of this Court, the order impugned passed by the Tax Board, affirming the order passed by the Deputy Commissioner (Appeals) does not suffer from any infirmity or illegality and it does not give rise to any question of law requiring the consideration of this Court. 16. In the result, the revision petition fails, it is hereby dismissed.