Reassessment of escaped turnover remains valid where prior appellate proceedings did not consider the same turnover.

Reassessment of escaped turnover under rule 31 of the A.P. General Sales Tax Rules, 1957 remains available where the turnover was not actually considered in prior appeal or revision. Section 14(4) authorises reassessment, and rule 31(6) limits that power only for escaped turnover already dealt with and finally disposed of under sections 19 or 20. The rule is read harmoniously with the parent Act to preserve appellate finality without defeating the power to tax escaped turnover. On that basis, reassessment was valid because the material forming the escaped turnover had not been examined by the appellate authority.

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Issues: Whether the assessing authority retained jurisdiction to reassess escaped turnover under rule 31 of the A.P. General Sales Tax Rules, 1957 after an appellate order had already been passed under section 19 of the A.P. General Sales Tax Act.

Analysis: Section 14(4) of the Act authorises reassessment of turnover that has escaped assessment. Rule 31(1) implements that power, while sub-rule (6) limits reassessment where the very escaped turnover has already been dealt with in appeal or revision under sections 19 or 20. The limitation in sub-rule (6) applies only to the turnover actually considered and finally dealt with by the appellate or revisional authority. It does not bar reassessment of turnover which escaped assessment and was not examined in the appellate proceedings. The rule must be read harmoniously with the parent statute so that finality of appellate orders is preserved without defeating the statutory power to tax escaped turnover.

Conclusion: The reassessment was valid because the material forming the basis of the escaped turnover had not been dealt with by the appellate authority, and the assessing authority was not barred by rule 31(6).

Ratio Decidendi: Rule 31(6) bars reassessment only of escaped turnover that has already been considered and disposed of in appeal or revision; it does not prevent reassessment of escaped turnover not dealt with by the appellate authority.

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