51. Period of limitation for Recovery of Tax:-

Notwithstanding anything contained in any law for the time being in force, no proceeding for recovery of any amount under sub-Section (7) and (8) of Section 43 and sub-Section (6) of Section 47 shall be initiated after the expiry of twelve years from the date of the relevant assessment.

Provided that when an appeal or revision has been filed, the period of limitation shall run from the date on which the amount due is finally determined.