ORDER A.K. Goel, C.J. 1. This order will dispose of W.P. (C) No. 3322 of 2010, W.P. (C) No. 3327 of 2010 and W.P. (C) No. 3267 of 2010 as it is stated that the issue involved is identical, i.e., whether the impugned reassessment orders are barred by limitation prescribed under section 19(2) of the Assam General Sales Tax Act, 1993. All the three writ petitions have been filed by the same assessee for three different assessment years. Proceedings for reassessments were initiated vide notice dated September 6, 2000 under section 18 of the Act and, thereafter, reassessment was completed on January 2, 2010/March 31, 2010, which is beyond the period of three years, stipulated under section 19(2) of the Act, and on that ground the same is sought to be quashed. We have heard learned counsel for the parties. 2. Since reassessment proceedings are patently hit by section 19(2) of the Act, we have called upon learned counsel for the Revenue to justify the same. His submission is that the period prescribed is not for passing the order of reassessment but for initiating reassessment proceedings or for completing the said proceedings without passing final order. He has placed reliance on the judgments of the honourable Supreme Court in State of Punjab v. Murlidhar Mahabir Parshad [1968] 21 STC 29 (SC), wherein section 11(4) and (5) of the Punjab General Sales Tax Act, 1948 came up for interpretation and in State of Tamil Nadu v. M.K. Kandaswami [1975] 36 STC 191 (SC): AIR 1975 SC 1871 , wherein section 7A of the Tamil Nadu General Sales Tax Act, 1954 came up for interpretation. In the first case, limitation prescribed was to "proceed to assess", while in the second case, observations relied upon are that interpretation should be purposive. 3. Both the above judgments are distinguishable. Limitation prescribed in the present statute is not for "proceeding to make assessment", but for "making assessment" in which case mere initiating proceedings is not enough but final order has to be passed within the prescribed time. 4. Relevant provisions of the Act: 18. 3. Both the above judgments are distinguishable. Limitation prescribed in the present statute is not for "proceeding to make assessment", but for "making assessment" in which case mere initiating proceedings is not enough but final order has to be passed within the prescribed time. 4. Relevant provisions of the Act: 18. Turnover escaping assessment.--(1) Where after a dealer has been assessed under section 17 for any year or part thereof, the assessing officer has reason to believe that the whole or any part of the turnover of a dealer in the respect of any period has escaped assessment to tax or has been under-assessed or has been assessed at a rate lower than the rate at which he is assessable, or any exemption or deduction or relief has been wrongly allowed or allowed in excess, the assessing officer may-- (a) in a case where the dealer has concealed, omitted or failed to disclose fully and truly the particulars of such turnover or furnished incorrect or incomplete particulars of his turnover or the rate of tax applicable to any part thereof or made incorrect claim for any exemption, deduction or relief, within eight years from the date of the relevant year for which or part of which the assessment or reassessment is required to be made; and (b) in any other case, within four years from the end of the relevant year for which or part of which an assessment or reassessment is required to be made; serve a notice on the dealer and, after giving the dealer an opportunity of being heard and making such inquiry as he considers necessary, proceed to determine to the best of his judgment, the amount of tax due from the dealer in respect of such turnover: 19. Time-limit for completion of assessment and re-assessment.-- (1).-- (2) No reassessment under section 18 shall be made-- (a) in a case falling under clause (a) of that section, after the expiry of three years; and (b) in a case falling under clause (b) of that section, after the expiry of one year from the end of the year in which the notice under that section is served on the dealer. 5. From the scheme of the statute it is clear that section 18(1) provides for limitation for initiating the reassessment while section 19(2) prescribes limitation for completing the assessment. 5. From the scheme of the statute it is clear that section 18(1) provides for limitation for initiating the reassessment while section 19(2) prescribes limitation for completing the assessment. In the present case, it is clear that completion of reassessment, i.e., passing of the order of reassessment is beyond the limitation prescribed under section 19(2). Accordingly, we allow these petitions and quash the orders of reassessment.