Reassessment limitation turns on the law in force when reopening power is exercised, defeating the time-bar challenge.

In taxing statutes, the validity of reassessment notices is tested against the law in force when the reopening power is exercised, not the law applicable to the earlier assessment year. Applying that principle and the earlier ruling on reassessment retrospectivity, the court treated the authority as having no vested right to act contrary to the law then in force. The limitation challenge to the notices therefore failed, and the later amendment to the incentive scheme did not alter the result. The reassessment proceedings were held not invalid on limitation grounds, and the revision petition failed.

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Issues: Whether the amended limitation provision governing reassessment proceedings applied to the notices issued for the relevant assessment years and rendered the reassessment time-barred.

Analysis: The governing principle applied was that, in taxing statutes, the power to reopen a completed assessment must be tested with reference to the law in force when that power is exercised, and not by the law as it stood during the earlier assessment year. The Court treated the issue as settled by the earlier decision on reassessment retrospectivity, which held that there is no vested right in the authority to exercise future power contrary to the law then in force. On that basis, the challenge that the reassessment notices were barred by limitation could not succeed. The additional argument based on the later amendment to the incentive scheme was also treated as not affecting the result.

Conclusion: The reassessment proceedings were not invalid on the ground of limitation, and the revision petition failed.

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