COMMISSIONER OF SALES TAX, MADHYA PRADESH vs M/S. AMARNATH AJITKUMAR OF BHIND, MADHYAPRADESH

The Supreme Court held that Section 12(1) of the Madhya Bharat Sales Tax Act prohibits the Commissioner from revising an assessment order after two years, while Section 39(2) of the Madhya Pradesh Sales Tax Act allows for a three-year period. The Court ruled that the repeal of the Madhya Bharat Act does not affect rights already acquired, thus the assessment must be governed by the provisions of the repealed Act. The appeal was dismissed, affirming that the Commissioner could not revise the order beyond the two-year limit set by the Madhya Bharat Act.