Limitation for reassessment under sales tax law runs to final determination of liability, not merely initiation of proceedings.

A fresh reassessment and the consequential notice were held to be invalid because they were issued after the four-year limitation period under section 14(1) of the Andhra Pradesh General Sales Tax Act, 1957, read with section 14(7). The court treated "assessment" as the final order determining liability, not merely the initiation of proceedings, and held that only the period between the original assessment and the setting aside of that assessment could be excluded. Even on that basis, both the notice and the reassessment order were beyond time, so the authority lacked jurisdiction to complete the reassessment.

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Issues: Whether a fresh assessment and the consequential notice issued after the expiry of the four-year limitation period prescribed by section 14(1) of the Andhra Pradesh General Sales Tax Act, 1957, read with section 14(7), were valid.

Analysis: Section 14(1) required assessment to be completed within four years from the expiry of the relevant assessment year. Section 14(7) permitted exclusion only of the period between the date of the original assessment and the date on which that assessment was set aside. On the facts, even after excluding the permissible period, both the notice proposing fresh assessment and the final order were issued beyond the extended limitation period. The expression "assessment" in this context referred to the final order determining liability, not merely initiation of proceedings, and therefore the authority lacked jurisdiction to complete the reassessment after time had expired.

Conclusion: The notice and the fresh assessment order were barred by limitation and without jurisdiction, and the writ petition was allowed.

Ratio Decidendi: Where a taxing statute requires assessment to be made within a specified period and the context shows that "assessment" refers to the final determination of liability, the assessing authority cannot validly complete a fresh assessment after the period expires, even if the proceedings were initiated earlier.

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