Correct disclosure before assessment defeats longer revision limitation; the shorter limitation period governs and late revision fails.

Where correct turnover particulars were furnished to the assessing authority before assessment was completed, the longer six-year limitation for failure to disclose correctly did not apply under section 14(4-A) of the A.P. General Sales Tax Act. The revision was governed by the shorter four-year period because the case fell within the category of under-assessment for reasons other than nondisclosure. As the revisional authority acted beyond that shorter period, the revision was time-barred and could not be sustained, and the original assessment was restored in favour of the assessee.

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Issues: Whether the revisional assessment was barred by limitation under section 14(4-A) of the A.P. General Sales Tax Act, and whether the longer period of six years applied on the ground of failure to disclose the turnover correctly.

Analysis: The turnover in dispute was described as stainless steel wheel discs and wheel caps during the assessment proceedings, and that description was before the assessing authority before completion of assessment. The relevant distinction under section 14(4-A) was between cases where the dealer failed to disclose the turnover or particulars correctly, attracting six years under clause (a), and cases where the escapement or under-assessment occurred due to any other cause, attracting four years under clause (b). Since the correct particulars were furnished during the pendency of the assessment proceedings, the case did not fall within clause (a). The revisional authority was therefore required to act within four years from the expiry of the relevant year.

Conclusion: The revision order was barred by time and was invalid; the assessee succeeded on the limitation issue.

Final Conclusion: The reassessment made by the revisional authority could not be sustained, and the original assessment was restored in favour of the assessee.

Ratio Decidendi: Where correct particulars of turnover are disclosed to the assessing authority before completion of assessment, the longer limitation period for failure to disclose correctly does not apply, and the shorter limitation period governs the revision.

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