Valid notice for CST reassessment may be inferred from linked proceedings where the same turnover is already in issue.

Reassessment under the Central Sales Tax Act, 1956 was treated as valid where the Bihar sales tax assessment and the CST assessment concerned the same turnover, the same financial year, and the same dispute over intra-State sale, inter-State sale, and stock transfer. Notices issued while giving effect to the remand order were accepted by the assessee and were held sufficient for reassessment under both enactments. In light of the linked statutory scheme under section 9(2), section 1(2A) of the CST Act and rule 12 of the Central Sales Tax (Bihar) Rules, 1957, the absence of a separate CST notice did not defeat jurisdiction.

---

---

Issues: Whether the reassessment order under the Central Sales Tax Act, 1956 was jurisdiction for want of a valid notice, and whether the petitioner could resist the reassessment on that ground.

Analysis: The assessments under the Bihar sales tax law and the Central Sales Tax Act related to the same turnover for the same financial year and arose out of the same dispute concerning intra-State sale, inter-State sale, and stock transfer. Notices issued in the course of giving effect to the remand order were accepted by the petitioner and were held to be applicable for reassessment under both enactments. The Court held that, in view of the interlinked nature of the assessments and the statutory scheme under section 9(2) and section 1(2A) of the Central Sales Tax Act, 1956 and rule 12 of the Central Sales Tax (Bihar) Rules, 1957, the challenge based on absence of a separate CST notice could not succeed.

Conclusion: The reassessment was not without jurisdiction for want of valid notice, and the challenge on that ground failed.

---