Determination of liability to pay tax

4.

1. (1) The Commissioner shall, in the prescribed manner, institute proceedings for the purpose of determining the liability of a hotelier or a proprietor to pay tax under this Act. Such liability shall be determined by an order and such determination shall be made within a period of twelve months from the date of institution of such proceedings.
2. (2) Notwithstanding anything contained in sub-section
3. (2) of Section 3, liability of a dealer to pay tax under this Act shall not be determined from a date earlier than five years prior to,
   • (i) the date of institution of proceedings under sub-section (1); or
   • (ii) the date of validity of the registration certificate, whichever is earlier.