Appellate remand keeps reassessment alive; limitation under sales tax law does not bar completion of validly commenced proceedings.

Reassessment proceedings initiated after an appellate remand were held to be a continuation of the original assessment, not a fresh initiation. The four-year limit in section 19 of the General Sales Tax Act, 1963 governs the commencement of escaped-turnover proceedings, not the completion of reassessment where proceedings were already lawfully set in motion within time. As the original assessment had been taken in appeal and remanded for fresh assessment, the subsequent action was not barred by limitation. The assessee's objection therefore failed, and the reassessment was permitted to proceed.

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Issues: Whether reassessment proceedings initiated after an appellate remand were barred by limitation under section 19 of the General Sales Tax Act, 1963.

Analysis: The four-year limit in section 19 governs the commencement of proceedings to determine escaped turnover, not the completion of the reassessment after proceedings have already been set in motion. Where an original assessment is taken in appeal and the appellate authority remands the matter for fresh assessment, the subsequent proceedings are a continuation of the original proceedings and not a fresh initiation. Assessment proceedings, once lawfully commenced, continue until their final termination by assessment, appeal, revision, or remand-based completion. The authorities relied on by the assessee did not alter this position on the facts before the Court.

Conclusion: The reassessment proceedings were not barred by limitation and the objection of the assessee failed.

Ratio Decidendi: A reassessment made pursuant to an appellate remand is a continuation of the original assessment proceedings, and the statutory period of limitation does not bar completion of proceedings that were validly commenced within time.

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