Escaped turnover reassessment limitation cannot be extended by assessment-time amendments under the Kerala sales tax law.

Section 17 and section 19 of the Kerala General Sales Tax Act operate in different fields: section 17 governs assessment, while section 19 is a self-contained escaped-turnover provision with an express five-year limitation. An extension of time for pending assessments under section 17 cannot enlarge the separate limitation under section 19 unless that provision is itself amended. Because no corresponding amendment to section 19 was shown, reassessment proceedings started and completed beyond the prescribed period were time-barred and could not be sustained.

---

---

Issues: Whether reassessment proceedings under section 19 of the Kerala General Sales Tax Act, 1963 were barred by limitation, and whether the extension of time for pending assessments under section 17 of the Act could enlarge the separate limitation prescribed for escaped turnover under section 19.

Analysis: Section 17 and section 19 operate in different fields. Section 17 governs assessment, while section 19 is a self-contained provision dealing with escaped turnover and expressly prescribes a five-year limitation. That statutory period cannot be diluted or extended by an amendment to section 17 unless section 19 itself is correspondingly amended. As no amendment altering the limitation under section 19 was shown, the reassessments initiated and completed beyond the prescribed period were time-barred.

Conclusion: The reassessment orders under section 19 were barred by limitation and could not be sustained.

---