Reassessment limitation under sales tax law applies when turnover is assessed at the wrong rate, not revisional time limits.

Where a higher authority reopens an assessment because turnover was assessed at an incorrect or lower rate, the action is treated as reassessment under section 14(4)(c) of the Andhra Pradesh General Sales Tax Act, not as revision under section 20. The limitation period therefore follows section 14(4-A), namely four years from the expiry of the assessment year, and the order is not saved by the revisional limitation counted from service of the assessment order. The Tribunal's view was affirmed and the limitation objection rejected.

---

---

Issues: Whether the Deputy Commissioner's order was a revisional order under section 20 of the Andhra Pradesh General Sales Tax Act or an exercise of reassessment powers under section 14(4), and consequently whether the order was barred by limitation.

Analysis: The order was found to deal with an assessment made at an incorrect rate and to seek assessment at the correct rate under clause (c) of section 14(4), which governs cases where turnover has been assessed at a lower rate. The limitation applicable to such an assessment was four years from the expiry of the assessment year under section 14(4-A). The revisional provision in section 20, including the four-year period counted from service of the assessment order, was held inapplicable because the impugned action was not a true exercise of revisional jurisdiction but an exercise of assessment power by a higher authority.

Conclusion: The order was time-barred under section 14(4-A) and not saved by section 20; the challenge to the Tribunal's view failed.

Final Conclusion: The revisions were dismissed, with the assessee's contention on limitation rejected and the Tribunal's determination affirmed.

Ratio Decidendi: Where a higher authority reopens an assessment because the turnover was assessed at a lower rate or at an incorrect rate, the action falls under the reassessment provision and is governed by the limitation attached to that provision, not by the limitation for revisional orders.

---