N. Ranga Rao And Sons vs State Of Karnataka And Ors

The Supreme Court held that the mere calling for records by the Additional Commissioner on 16.3.1996 does not constitute an exercise of power under Section 15(4) of the Karnataka Tax on Entry of Goods Act, 1979, thereby rendering the subsequent show cause notice issued on 20.5.1996 beyond the limitation period of four years from the First Appellate Authority's order dated 28.3.1992. The Court emphasized that the initiation of proceedings must be through a formal show cause notice, which was not the case here. Consequently, the appeal was allowed, and the High Court's decision was set aside.