Reassessment after remand remains subject to limitation for escaped assessment, making late completion without legal authority.

Reassessment proceedings after remand remained subject to the limitation period governing escaped assessments under rule 33(1) of the General Sales Tax Rules. The court rejected the argument that the rule applied only to original or suo motu assessments, holding that neither an original assessment nor a reassessment can validly be completed after the prescribed time-limit. The fact that the limitation was set out in a rule rather than the parent Act made no legal difference. The later assessment and the appellate order were therefore outside the permissible period and liable to be quashed.

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Issues: Whether reassessment proceedings initiated after remand could validly continue when they were commenced and completed beyond the period of limitation prescribed by rule 33(1) of the General Sales Tax Rules.

Analysis: The proceedings were treated as relating to escaped assessment. The attempt to confine rule 33 to original or suo motu assessments was rejected in light of the principle that neither an original assessment nor a reassessment can be made beyond the statutory period of limitation. The fact that the limitation here was found in a rule, rather than in the parent Act, made no legal difference. The later assessment and the appellate order were therefore outside the permissible time-limit.

Conclusion: The reassessment proceedings were barred by limitation and the impugned orders were liable to be quashed.

Ratio Decidendi: A reassessment made after remand is still subject to the statutory limitation governing escaped assessment, and an assessment completed beyond that period is without legal authority.

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