M. C. AGARWAL, J. - (1.) These are four revision petitions under section 11 of the U. P. Sales Tax Act, 1948, directed against a common order dated 4th of August, 1992 passed by the Sales Tax Tribunal, Kanpur Bench II, whereby it dismissed the assessee-revisionist's appeals for assessment years 1976-77, 1977-78 and 1978-79 and partly allowed the appeal for assessment year 1975-76. The revisionist is a co-operative society engaged in the business of production and sale of soap, a commodity liable to sale tax under the U. P. Sales Tax Act, 1948. It applied for a recognition certificate in terms of section 4b of the U. P. Sales Tax Act. Such a certificate was granted to it, vide order dated 17th of June, 1974 and was effective from 28th of May, 1974. According to the recognition certificate granted to the revisionist it was entitled to full exemption from payment of sales tax on the purchases of raw materials made by it. Such certificate was renewed from time to time and was in force during the assessment years under consideration. In pursuance of the said recognition certificate the revisionist made purchases of raw materials and issued declarations in form III-B declaring that it was entitled to full exemption from sales tax. Accordingly the selling dealers did not charge any sales tax from the revisionist. The turnover of the sale of soap by the revisionist was in pursuance of the said recognition certificate treated as exempt from tax. Somewhere in the year 1988, the department suddenly woke up and noticed that the revisionist had got the recognition of the Khadi and Village Industries Board and accordingly its sales were exempt from tax, even without the recognition certificate and in accordance with the notification dated 30th of May, 1975, no recognition certificate could be issued to the revisionist. Thus, according to the Revenue the revisionist had issued false or wrong declarations in form III-B furnished to its sellers. The Sales Tax Officer, therefore, initiated action under section 3b and ultimately passed the impugned order dated 24th of December, 1988, levying on the assessee the amount that would have been charged from it as sales tax if the declarations had not been so made. The revisionist preferred appeals to the Assistant Commissioner (Judicial), but failed. It preferred second appeals before the Sales Tax Tribunal. As stated above, the appeals for assessment years 1976-77, 1977-78 and 1978-79 were dismissed but the appeal for the assessment year 1975-76 was partly allowed because the notification dated 30th of May, 1975 had come into force within the assessment year and, therefore, declarations issued prior to that date were not wrong. The Tribunal, therefore, restored the matter to the Sales Tax Officer to determine the amount payable in terms of section 3b after the commencement of the said notification. Section 4b (1) (b) of the U. P. Sales Tax Act under which the recognition certificate in question was granted to the revisionist reads as follows : " Where any goods liable to tax under any other provision of this Act are sold by a dealer to another dealer and such other dealer furnishes to the selling dealer in the prescribed form and manner a certificate to the effect that he holds a recognition certificate issued under sub-section (2) in respect thereof, the selling dealer shall be liable in respect of those goods to tax at such concessional rate, or be wholly or partly exempt from tax, whether unconditionally or subject to the conditions and restrictions specified in that behalf, as may be notified in the Gazette by the State Government in that behalf. " In pursuance of this provision the Government issued a notification dated 11th of June, 1974, prescribing the conditions under which recognition certificate could be granted. It is under this notification that the recognition certificate was initially granted to the revisionist and admittedly the initial recognition certificate was correctly issued to the revisionist. Later the Government issued another notification dated 30th of May, 1975, which provided that no concession shall be admissible if the goods manufactured by the unit are not liable to tax at any stage under the Act. It is because of this notification that the assessee became disentitled to the concession under section 4b because it being a unit recognised by the Khadi and Village Industries Board its sales were not liable to tax under the Act and consequently the notification dated 30th of May, 1975 disentitles such a person from claiming any further relief under section 4b. Thus, according to the Revenue after the issue of the notification dated 30th of May, 1975, the revisionist was not entitled to the issue of a recognition certificate and the issue of such certificate to the revisionist was wrong and consequently the declarations issued by the revisionist in form III-B were false or wrong within the meaning of section 3b. The relevant portion of the declaration in form III-B reads as under : " Certified that the goods specified below ordered for in my/our purchase order No. . . . dated. . . . . . purchased from you as per bill/cash memo No. . . . . . . . dated. . . . . . . . supplied under challan/invoice No. . . . . . dated. . . . . are for use as raw material in the manufacture of goods notified under notification No. . . . . . . dated. . . . . . . and that the said manufactured goods would be sold in the manner contemplated in sub-section (2) of section 4b. Certified that I hold the recognition certificate No. . . . issued to me/us by the Sales Tax Officer. . . . Circle No. . . . dated. . . . and which is effective from. . . . . . . certified that I/we carry on business at. . . . . . . . . (full address) under the name and style of. . . . . . . . . . " The important facts that this form requires to be declared are (i) that the raw materials to be purchased would be used as raw material in the manufacture of goods notified under a notification and sold in the manner contemplated in sub-section (2) of section 4b and (ii) that the purchaser of the raw materials holds a recognition certificate. Admittedly soap is one of the notified goods under all the notifications issued by the Government from time to time and the revisionist did possess a recognition certificate issued by the department at all the relevant times. None of the authorities below have in their long orders stated which statement contained in the declarations in form III-B issued by the revisionist to its sellers was wrong or false. The learned Standing Counsel candidly admitted that so far as the declarations in form III-B are concerned, no incorrect statement was made by the revisionist, but contended that since the sales of the revisionist were exempt from tax before of its recognition by the Khadi and Village Industries Board, the recognition certificate granted to the assessee under section 4b was wrongly issued and because of the issue of a wrong recognition certificate to which the dealer was not entitled, the declarations in form III-B should also be deemed to be wrong or false. I am unable to subscribe to such a view. Section 3b is a provision in a taxing statute imposing financial burden on a trader and its requirements must be strictly met if any liability is intended to be imposed on a businessman. As demonstrated above, the declarations in form III-B issued by the revisionist were in accordance with the recognition certificate granted to it by the Sales Tax Department and any error in the said certificate which was not the result of any misconduct on the part of the dealer and was patently not in contemplation of the department as well as the dealer at the relevant time cannot make the statements made by the revisionist in form III-B wrong or false. The Revenue cannot burden the dealer with the consequences of its own ignorance. In Massay Engineering Works v. Commissioner of Sales Tax 1987 UPTC 1406 a learned single Judge of this Court has held that where the declaration in form III-B is in conformity with the recognition certificate issued to a dealer such declaration cannot be termed to be wrong or false. Thus, the view that I have expressed above, finds support from an earlier judgment of this Court and accordingly I hold that the declarations issued by the revisionist in form III-B were neither wrong nor false and, therefore, no liability could be raised against the dealer. At the hearing the learned counsel for the revisionist prayed that he be allowed to raise another question of law that the action taken by the Sales Tax Officer in ultimately passing the impugned order dated 24th December, 1988, was barred by time. In exercise of powers under sub-section (4) of section 11, I allow the revisionist to raise this question of law. As stated above, the proceedings relate to assessment years 1975-76, 1976-77, 1977-78 and 1978-79. The impugned orders were passed in December, 1988, i. e. , more than eight years after the end of the last of the assessment years. Sub-section (2) of section 21 of the Act provides that except as otherwise provided in this section no order of assessment or reassessment under any provision of this Act for any assessment year shall be made after the expiration of four years from the end of such year. Thus, if the impugned order passed by the Sales Tax Officer raising the disputed demands on the assessee is an order of assessment, then the impugned orders in all the four years are barred by time. The learned Standing Counsel contended that an order passed by the Sales Tax Officer under section 3b of the Act is not an order of assessment and for this view he placed reliance on a judgment of a learned single Judge of this Court in Commissioner of Sales Tax v. R. S. Steel Works, Bareilly 1987 UPTC 28. In this judgment a view has been taken that an amount levied on a dealer in terms of section 3b is only an amount and is not tax. In my view this view requires reconsideration because an amount levied on a dealer under the Sales Tax Act has to have the nature of tax, fee, interest or penalty and if it is neither of these and is just an "amount" then there is no provision under the Sales Tax Act under which such an amount can be demanded and recovered from the dealer. However, in the present case I do not consider it necessary to record any final opinion on this point because what is necessary to determine is not the nature of the amount, but the nature of the determination. If the determination is an "assessment" within the meaning of the Act, then the limitation prescribed in section 21 (2) would apply. Assessment has not been defined in the Act. Assessment in its ordinary parlance in relation to taxing statute means to determine the rate or amount as a tax or to impose as a tax according to an established rate or to make an official valuation for purposes of taxation. Under section 3b the Sales Tax Officer has to determine the amount of sales tax which would have been payable by the assessee on the purchases made by it had it not issued a false or wrong certificate or declaration and to make an order directing the assessee to pay such amount. This determination of the amount payable by an assessee which is equivalent to the sales tax that it would have otherwise paid is in my view an assessment under the Sales Tax Act. If this is not so, then a queer situation will arise because in spite of the determination of such amount the same cannot be demanded and recovered from an assessee. Section 7 of the Act deals with the determination of turnover and assessment of tax. After the tax is assessed, a demand notice has to be issued under sub-section (1-A) of section 8 which lays down that the tax assessed under this Act shall be deposited in the manner specified in, and within thirty days of the service of notice of assessment and demand. There is no other provision in the Act under which an order passed under section 3b and a demand notice in pursuance thereof could be served on a dealer. Sub-section (9) of section 8 deals with the effect of appellate proceedings and it uses the words "where any notice of assessment and demand in respect of any tax or other dues under this Act is served upon a dealer". These words show that even when the amount levied on a dealer under the Act is not of the nature of tax and comes under the category "other dues" what has to be served on the dealer is a notice of assessment and demand. The use of the word "and" clearly indicates that a notice of demand had to follow an assessment. Then in sub-clause (c) of section 8 (9) it is stated that no fresh notice shall be necessary in any case where the amount of tax or other dues is not enhanced (with reference to the amount assessed by the assessing authority) as a result of such appeal, revision or other proceedings. This languages also clearly indicates that even the "other dues" have to be "assessed" by the assessing authority. It necessary follows that the process by which the assessing authority determines the amount of dues other than sales tax payable by a dealer has to be the process of assessment and the period of limitation provided by the statute under section 21 (2) has to be adhered to. Leaned counsel for the revisionist Sri Rajesh Kumar Agarwal placed reliance on a judgment of the honourable Andhra Pradesh High Court in State of Andhra Pradesh v. Sri Ganesh Bhavan Hotel [1983] 53 STC 169 in which in relation to the Andhra Pradesh General Sales Tax Act it was held that when no limitation for the levy of penalty was prescribed, the limitation prescribed for the making of assessment would apply to levy of penalty also. No support need be taken from this judgment because as shown above the determination of an amount payable by a dealer under section 3b of the Sales Tax Act, 1948, is an assessment and the Act specifically provides the period of limitation for assessment. Accordingly I hold that the impugned orders dated 24th of December, 1988 were passed by the Sales Tax Officer concerned much after the expiry of the period of limitation and, therefore, could not have been sustained. For the reasons discussed above, these revisions are allowed and the impugned orders dated 24th of December, 1988 passed by the Sales Tax Officer are, hereby quashed. In the circumstances of the case of parties are made to bear their own costs. Petitions allowed. .;