Strict scope of remand and exemption interpretation limits reassessment jurisdiction and keeps writ challenge to show-cause notices premature.

Exemption under a sales tax notification must be applied strictly within its terms, and any later interpretation may be urged before the statutory authority. Where an assessment order is quashed and the matter is remitted for reconsideration, the authority's jurisdiction on remand remains confined to the same statutory field originally invoked in the rectification proceedings. The authority cannot enlarge the controversy beyond rectification, and the petitioner cannot seek adjudication outside that limited scope at the notice stage. In this setting, writ petitions challenging show-cause notices were not entertained, and objections were to be raised before the assessing authority within the time granted.

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Issues: Whether the writ petitions challenging the show-cause notices were maintainable, and whether the assessing authority, on reconsideration after remand in rectification proceedings, could travel beyond the scope of section 25-A of the Karnataka Sales Tax Act, 1957.

Analysis: The assessment liability had already been determined, and the petitioner's claim to concession arose from an exemption notification issued under section 8-A of the Karnataka Sales Tax Act, 1957. The Court held that exemption must be confined strictly to the terms of the notification, and that the petitioner could urge any later interpretation of the notification before the statutory authority. The Court further held that when an assessment order is quashed and the matter is remitted for reconsideration, the authority's jurisdiction on remand remains confined to the same statutory field in which the original rectification application was made. The authority therefore could not enlarge the controversy beyond rectification, and the petitioner likewise could not demand adjudication beyond that jurisdiction at the stage of notice.

Conclusion: The writ petitions were not entertained, and the petitioner was directed to raise objections before the assessing authority within the time granted.

Ratio Decidendi: When a matter is remitted for reconsideration after judicial review, the authority's jurisdiction on remand is limited to the same statutory power originally invoked, and writ interference against show-cause notices is unwarranted where the statutory authority must first decide the objections within that confined jurisdiction.

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