Reassessment jurisdiction upheld where express commissioner authorisation covered VAT scrutiny assessment, not deemed assessment on returns alone.

Reassessment was upheld as within jurisdiction because the assessment dated 09.01.2014 was treated as a scrutiny assessment made after calling for and examining books of account, not a deemed assessment based only on returns. The Commissioner's later order under the governing rule was treated as express authorisation for the transferee officer to reassess the relevant VAT year, satisfying the jurisdictional requirement. The objection that the earlier audit reference mentioned CST rather than VAT was rejected because the operative part of the authorisation specifically covered the VAT transaction. Reassessment was therefore valid, and the challenge to the notice and reassessment order failed.

---

---

Issues: Whether the reassessment notice and order were without jurisdiction on the ground that the earlier order was under the deemed assessment provision and that the officer issuing reassessment was not validly authorised under the relevant rule.

Analysis: The assessment dated 09.01.2014 was treated as an assessment made after calling for and scrutinising books of account, and not as a deemed assessment based merely on returns. The Commissioner's order under the relevant rule, read with the reassessment provision, was found to be an express authorisation empowering the transferee officer to undertake reassessment for the assessment year in question. The objection that the reassessment related to VAT whereas the initial audit reference mentioned CST was rejected, since the operative part of the Commissioner's later order specifically authorised reassessment of the VAT transaction. The earlier decision relied upon by the petitioner was distinguished because the present record contained a specific authorisation.

Conclusion: The reassessment proceedings were held to be valid and within jurisdiction, and the challenge to the notice and reassessment order failed.

Ratio Decidendi: Reassessment under the Act is valid only when made by an officer expressly authorised by the Commissioner under the governing rule, and an assessment made after scrutiny of books of account is not a deemed assessment merely because returns were filed.

---