Reassessment after revisional remand remains subject to statutory limitation and is not an open-ended revival of assessment power.

Where a revisional authority remands a sales tax assessment for fresh assessment, the reassessment is treated as a fresh statutory proceeding and not an unrestricted continuation of the original assessment. The assessing authority must therefore act within the limitation period prescribed for reassessment under the sales tax law. This limitation applies even where the original assessment was completed on a best judgment basis, because the controlling time-limit remains the one governing reassessment. On that reasoning, the reassessment was held to be barred by limitation and without jurisdiction.

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Issues: Whether reassessment proceedings initiated after an order of remand under revisional jurisdiction are governed by the limitation prescribed for reassessment under the sales tax law.

Analysis: The revisional authority's order setting aside the original assessment and directing a fresh assessment did not create an unrestricted continuation of the earlier assessment proceedings. Once the matter was sent back for reassessment, the assessing authority had to proceed within the statutory time-limit applicable to reassessment. The same principle applied even where the original assessment had been made on a best judgment basis, because the limitation applicable to such assessments remained the controlling provision. The legal position was supported by the principle that a reassessment following remand is a fresh proceeding and not an unlimited revival of the original assessment power.

Conclusion: The reassessment was barred by limitation and the challenge to the High Court's interference failed.

Final Conclusion: The appeal was rejected and the order holding the reassessment without jurisdiction was maintained.

Ratio Decidendi: Where a revisional authority remands a sales tax assessment for fresh assessment, the reassessment is a fresh statutory proceeding governed by the applicable limitation period for reassessment.

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