Tribunal observations cannot prejudice parties' rights in reassessment proceedings; limitation and validity were left undecided.

The revision was confined to the effect of the Tribunal's observations on the parties' rights in reassessment proceedings. The Court held that those observations would not prejudice either party and would have no operative effect on their rights. It did not decide whether the reassessment was completed within the prescribed period or whether delay rendered it invalid. The merits of limitation and the validity of the reassessment were expressly left open for determination in an appropriate proceeding.

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Issues: Effect of the Tribunal's observations on the parties' rights in relation to reassessment proceedings and whether the revision required adjudication on the merits of limitation.

Analysis: The revision was confined to the effect of the observations made in the Tribunal's judgment. The Court did not enter upon the controversy whether the reassessment was within the prescribed period or whether it was invalid for delay. It noted that, if reassessment had not been completed within time, invalidity would follow on that ground, but that question was not decided. The Court further held that the impugned observations in the Tribunal's judgment should not prejudice the parties' rights.

Conclusion: The revision was disposed of by clarifying that the Tribunal's observations would have no effect on the rights of the parties, while leaving the merits of limitation and validity of reassessment undecided.

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