Duplicate reassessment for concluded tax periods is without jurisdiction and cannot stand under settled proceedings.

A second reassessment covering the same tax periods under the Central Sales Tax Act and the Karnataka Value Added Tax Act was held unsustainable because the earlier reassessment for those periods had already been completed by the designated authority. The later notice and order were treated as a duplication of concluded proceedings, and the court found the subsequent exercise to be without jurisdiction. The reassessment order was therefore illegal, bad in law, and set aside in favour of the assessee.

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Issues: Whether the second reassessment order for the same tax periods was jurisdiction and liable to be set aside as a duplication of earlier concluded proceedings.

Analysis: The petitioner had already been subjected to reassessment for the relevant periods under the Central Sales Tax Act and the Karnataka Value Added Tax Act. The later notice and reassessment order covered the same periods and proceeded notwithstanding the earlier order already passed by the designated authority. In these circumstances, the subsequent proceedings amounted to a exercise over a matter that had already been concluded, rendering the later order unsustainable.

Conclusion: The reassessment order was illegal and bad in law and was set aside in favour of the assessee.

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