Reassessment limitation under sales tax law turns on making the order in time, not mere late communication, absent unexplained delay.

Reassessment under section 14(4-A) of the A.P. General Sales Tax Act is not time-barred merely because the order is communicated after four years from service of the original assessment order. The statutory focus is on whether the reassessment order was made within the limitation period; prompt service is relevant only where delay is unexplained, inordinate, or suggests ante-dating. The cited precedents were read narrowly and did not create a general rule that late communication alone invalidates reassessment. On the stated facts, there was no unexplained delay or plea of ante-dating, so the limitation challenge fails.

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Issues: Whether the reassessment under section 14(4-A) of the A.P. General Sales Tax Act was barred by limitation because the escaped assessment order was passed and served beyond four years from service of the original assessment order, and whether the cited precedents required prompt communication of the reassessment order as a condition of validity.

Analysis: The Court held that the earlier Supreme Court decision did not lay down any general rule that every reassessment order communicated after four years is automatically time-barred. That decision turned on peculiar facts suggesting possible ante-dating and unexplained delay in service. The later High Court decision relied upon by the assessee was also understood only to require prompt communication as a matter of fairness and propriety, not as an independent limitation requirement. On the facts, the Court found no unexplained or inordinate delay and noted that no plea of ante-dating had been raised before the authorities or in the Court.

Conclusion: The reassessment was not barred by limitation and the challenge to the escaped assessment failed.

Ratio Decidendi: Mere communication of a reassessment order beyond four years does not by itself render the order time-barred; limitation under the Act depends on the making of the order within the statutory period, while prompt service is relevant only where the delay is unexplained or suggests ante-dating.

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