Escaped assessment cannot proceed while remanded original assessment remains pending before the assessing authority.

Turnover cannot be treated as escaped assessment while the original assessment remains pending after remand, because the entire matter is again before the assessing authority and no final assessment order has been made. Proceedings for escaped assessment under section 21 cannot run simultaneously with the remanded assessment proceedings. The effect is that escaped assessment action must await completion of the original reassessment process, and the assessee succeeds on that legal point.

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Issues: Whether proceedings for escaped assessment under section 21 could continue when the original assessment proceedings had been remanded and were still pending.

Analysis: A turnover cannot be treated as escaped assessment while the original assessment proceedings remain pending and no final order has been made. Once the appellate authority remands the original assessment, the entire matter is open before the assessing authority. In that situation, proceedings for escaped assessment cannot run simultaneously with the remanded assessment proceedings.

Conclusion: The proceedings under section 21 could not continue after remand of the original assessment proceedings, and the assessee succeeded on the question of law.

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