However, the Commissioner may for reasons to be recorded in writing, extend such time limit in any particular case by a period not exceeding six months.

Assessment in case of avoidance or evasion of tax Assessment in case of avoidance or evasion of tax.-

1. (1) Where the Assessing Authority or any officer authorized by the Commissioner in this behalf has reasons to believe that a dealer has avoided or evaded tax or has not paid tax in accordance with law or has availed input tax credit wrongly or erroneously refunded, he may after giving the dealer a reasonable opportunity of being heard, determine at any time and for any period, that taxable turnover of such dealer on which tax has been avoided or evaded or has not been paid in accordance with law or wrong input tax credit has been availed or erroneously refunded and assess the tax to the best of his judgment in such time and manner as may be prescribed.
2. (2) No assessment order under this section shall be passed after the expiry of three years from the end of the relevant year.