Compounding assessments cannot be reopened on revised prior-year assessments; rectification is limited to the original authority and time-barred.

Compounding under Section 7 of the Kerala General Sales Tax Act is governed by a prescribed formula, and the assessee's liability is fixed by the higher of the computed figures. The reference to earlier years in that formula relates only to turnover tax admitted in the return, accounts, or actually paid, not to assessed tax; revised assessments for prior years therefore do not justify reopening completed compounding proceedings. Once the option for compounding is accepted, only apparent computational mistakes may be rectified. Any such rectification power under Section 43 lies with the original authority and must be exercised within three years from the date of the order.

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Issues: Whether assessments completed on compounded basis under Section 7 of the Kerala General Sales Tax Act could be reopened on the basis of revised assessments for prior years, and whether rectification of compounding orders was barred by the limitation under the statute.

Analysis: The compounding scheme under Section 7 operates on a prescribed formula and the assessee's liability is determined by choosing the higher of the two computed figures. The reference to earlier years in the formula is only to the turnover tax payable as conceded in the return or accounts or actually paid, and not to assessed tax. Since assessed tax may be altered in later proceedings, it is not a relevant basis for reopening completed compounding proceedings. The option to pay tax at compounded rates is an alternative to regular assessment, and once accepted, the proceedings can be reopened only to the limited extent of rectifying apparent computational mistakes. Even where rectification is permissible, Section 43 confines that power to the authority that passed the original order and requires exercise within three years from the date of that order.

Conclusion: Reopening of concluded compounding proceedings on the basis of revised prior-year assessments was not sustainable, and rectification beyond the statutory three-year period was barred.

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