Reassessment of total turnover is permitted when newly discovered sales show the whole year escaped assessment.

Section 14(4)(a) of the Andhra Pradesh General Sales Tax Act permits reassessment where turnover has escaped assessment in whole or in part. If originally accepted turnover below the taxable limit is later combined with newly discovered turnover and the total shows that the whole turnover for the year escaped assessment, the assessing authority may reassess the entire turnover to the best of its judgment. The originally disclosed turnover does not remain immune merely because it had earlier been accepted. The Tribunal's view was set aside and the reassessment of total turnover was restored.

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Issues: Whether, in proceedings under section 14(4) of the Andhra Pradesh General Sales Tax Act, the assessing authority could include originally disclosed turnover, which had been accepted below the exemption limit and later combined with newly discovered turnover, while making reassessment.

Analysis: Section 14(4) authorises reassessment where the whole or any part of the turnover has escaped assessment to tax, has been under-assessed, or has been assessed at a lower rate. The opening words and clause (a) permit the assessing authority to determine to the best of his judgment the turnover that has escaped assessment and assess the turnover so determined. Where the original return was accepted as below the taxable limit and subsequent inquiry disclosed further turnover, the combined turnover could show that the whole turnover for the year had escaped assessment. In such a situation, the authority was entitled to assess the total turnover under section 14(4)(a), and the original accepted turnover did not remain immune from reassessment.

Conclusion: The assessing authority had jurisdiction under section 14(4)(a) to add the originally disclosed turnover to the newly discovered turnover and levy tax on the total turnover.

Final Conclusion: The Tribunal's view was set aside and the reassessment made by the assessing authority, as affirmed in appeal, was restored.

Ratio Decidendi: Where newly discovered turnover, when added to turnover earlier accepted below the taxable limit, shows that the whole turnover has escaped assessment, section 14(4)(a) authorises reassessment of the total turnover and not merely the newly discovered part.

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