Limitation for revisional action on escaped turnover runs from service of the original assessment order, not a post-remand order.

Escaped turnover could be brought to tax under the assessment and revisional powers, but action had to be initiated within four years from service of the original assessment or levy order on the dealer. Where the escaped turnover was not the subject of remand proceedings, a fresh order passed after remand did not restart the limitation period for that omitted turnover. The limitation therefore ran from service of the original assessment order, and on that basis the revisional order was beyond time and barred by limitation.

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Issues: Whether the order revising the assessment was barred by limitation, and whether the period of four years under the Act had to be computed from the date of service of the original assessment order or from the date of service of the fresh order passed after remand.

Analysis: Section 14(4) empowered the assessing authority, and by virtue of Section 14(4-C) the higher revisional authorities as well, to bring to tax turnover that had escaped assessment. Section 14(4-A) required such action to be taken within four years from the date on which the order of assessment or levy was served on the dealer. The escaped turnover was not the subject-matter of the remand proceedings, and the fresh assessment made after remand did not govern the limitation for action on the escaped turnover. Since the omission related to the original assessment, the limitation had to run from the service of the original assessment order. On that footing, the revisional order was beyond time.

Conclusion: The revisional order was held to be barred by limitation and the challenge to it failed.

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