Reassessment limitation under sales tax law upheld where amended period applied before any vested immunity accrued.

Section 9(2) of the Central Sales Tax Act permits State sales tax authorities to assess and reassess Central sales tax matters under the State Act, and section 12A of the Karnataka Sales Tax Act supplied the relevant limitation period for reassessment. Because that limitation period was enlarged by amendment before any vested immunity from reassessment had accrued, the amended law governed the reassessment. The reassessment was therefore within the extended period and was not barred by limitation, so the jurisdictional objection failed.

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Issues: Whether reassessment for the assessment year 1981-82 was barred by limitation in view of section 12A of the Karnataka Sales Tax Act, 1957.

Analysis: Section 9(2) of the Central Sales Tax Act, 1956 authorises the State sales tax authorities to assess and reassess Central sales tax matters in accordance with the State Act. Section 12A of the Karnataka Sales Tax Act, 1957 prescribed the period of limitation for reassessment, and that period had been enlarged by legislative amendment before any immunity from reassessment could have accrued to the assessee. Where no vested immunity has yet arisen, the Legislature is competent to enlarge the period of limitation, and the amended law governs the reassessment made within the extended period.

Conclusion: The reassessment order was not barred by limitation and the objection to jurisdiction failed.

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