Limitation for second reassessment runs from original assessment, not earlier reassessment, under the sales tax law.

The five-year limitation period for a second reassessment under section 19(1) of the M.P. General Sales Tax Act, 1958 was held to run from the original assessment under section 18, not from an earlier reassessment order. The expression "order of assessment" was construed to mean the original assessment, and the amendment to section 19(1) did not change that position. Reliance on revisional limitation principles was found misplaced because the dispute concerned reassessment under section 19(1), not revision under section 39(1). On that basis, the second reassessment notice, the reassessment order and the consequential revisional order were treated as barred by limitation.

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Issues: Whether the five-year period of limitation for initiating a second reassessment under section 19(1) of the M.P. General Sales Tax Act, 1958 was to be computed from the date of the original assessment or from the date of the first reassessment order.

Analysis: The expression "order of assessment" in section 19(1) was held to mean the original assessment made under section 18 and not an earlier reassessment order. The amendment to section 19(1) did not alter that position, and the revisional authority's reliance on the bar under revisional limitation principles was misplaced because the present controversy concerned reassessment under section 19(1), not revision under section 39(1).

Conclusion: The limitation period had to be computed from the original assessment order, and the second reassessment notice and the consequential reassessment and revisional orders were barred by limitation and liable to be quashed.

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