Reassessment on later legal information upheld where escaped turnover could be acted on and statutory remedies barred writ relief.

Later judicial information can validly support reassessment where section 12(1) permits action if turnover has escaped assessment for any reason, and the provision is broader than a "reason to believe" test. The Court held that a later clarification on the taxability of woollen felts constituted relevant jurisdictional material, so the reassessment notices were valid. It also held that writ relief was ordinarily unavailable because the Rajasthan Sales Tax Act provided an efficacious statutory remedy structure, and no exceptional jurisdictional defect or palpable injustice was shown. The challenge to the reassessment notice therefore failed.

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Issues: (i) Whether the assessing authority could reopen the assessment under section 12(1) of the Rajasthan Sales Tax Act on the basis of later legal information and a fresh view on the taxability of woollen felts. (ii) Whether the writ petition was maintainable in view of the statutory remedies available under the Rajasthan Sales Tax Act.

Issue (i): Whether the assessing authority could reopen the assessment under section 12(1) of the Rajasthan Sales Tax Act on the basis of later legal information and a fresh view on the taxability of woollen felts.

Analysis: The provision was read as empowering reassessment where, for any reason, turnover had escaped assessment. The Court distinguished this language from the narrower "reason to believe" formulation in the income-tax reassessment provisions and held that the later judicial clarification that woollen felts were not woollen fabrics constituted relevant information bearing on escaped assessment. The notices were thus supported by jurisdictional material and were not invalid merely because the original assessment had proceeded on a different view.

Conclusion: The reopening under section 12(1) was held to be valid and within jurisdiction, against the assessee.

Issue (ii): Whether the writ petition was maintainable in view of the statutory remedies available under the Rajasthan Sales Tax Act.

Analysis: The Rajasthan Sales Tax Act was treated as a complete code providing appellate, revisional and other remedies. In the absence of a jurisdictional nullity or palpable injustice, the existence of those remedies barred interference under article 226. The Court found no sufficient ground to bypass the statutory machinery.

Conclusion: The writ petition was held to be not maintainable on the ground of alternative remedy, against the assessee.

Final Conclusion: The challenge to the reassessment notice failed, and the petition was dismissed for want of merit and in view of the statutory remedy structure.

Ratio Decidendi: Under a reassessment provision using the words "for any reason," later legal information can validly found a belief that turnover has escaped assessment, and writ relief will ordinarily be refused where an efficacious statutory remedy exists.

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