Reassessment limitation is procedural: amended six-year period applied to pending liability, and the challenge failed.

A procedural limitation period for reassessment was held not to be a vested right, so the assessee could not rely on the earlier three-year period where it had not expired before the new Act came into force. The repeal-and-saving scheme preserved subsisting liabilities and enabled the amended six-year reassessment period to apply, defeating the challenge on limitation and jurisdiction. On the facts, the reassessment also fell under section 14(3) of the Andhra Pradesh General Sales Tax Act, 1957, rather than section 14(4), so objections based on the old procedure failed. The reassessment was upheld and the revision dismissed with costs.

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Issues: (i) whether the repeal and saving provision preserved only the substantive tax liability and not the pre-existing three-year period for reassessment, so that the amended six-year period under the new Act applied; (ii) whether the reassessment proceedings were governed by section 14(3) of the Andhra Pradesh General Sales Tax Act, 1957, and not by section 14(4).

Issue (i): whether the repeal and saving provision preserved only the substantive tax liability and not the pre-existing three-year period for reassessment, so that the amended six-year period under the new Act applied.

Analysis: The saving clause preserved rights, liabilities, and actions already accrued or incurred under the repealed law, but the Court held that the period within which escaped turnover could be reassessed was part of procedure and a fetter on jurisdiction, not a vested or accrued right. A taxpayer has no vested right in a particular procedural time-limit for reassessment. Since the original three-year period had not expired when the new Act came into force, the enlarged period introduced by the later amendment operated on the pending liability. The repeal and saving scheme also showed a contrary intention sufficient to exclude the general savings rule and to apply the new machinery to subsisting rights and liabilities.

Conclusion: The amended six-year period governed the reassessment, and the challenge based on limitation and want of jurisdiction failed.

Issue (ii): whether the reassessment proceedings were governed by section 14(3) of the Andhra Pradesh General Sales Tax Act, 1957, and not by section 14(4).

Analysis: The Court held that, on the facts, the proceedings fell within section 14(3) and not section 14(4). Once the repeal and saving provision were applied, the reassessment had to be tested under the new Act's machinery as brought into force by the saving clause, and the objections founded on the old Act's procedure could not prevail.

Conclusion: Section 14(3) applied, and the contention that section 14(4) governed the case was rejected.

Final Conclusion: The reassessment was upheld as having been made within the permissible period and under the proper statutory machinery, so the revision was dismissed with costs.

Ratio Decidendi: A statutory period for reopening or reassessment is procedural and does not create a vested right in the assessee; where the earlier period has not expired before the new law with a longer period comes into force and the repeal-and-saving scheme evinces a contrary intention, the amended reassessment provision applies to subsisting liabilities.

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