Limitation for reassessment under Section 12-A cannot be extended by a judgment in another case against a stranger to earlier proceedings.

Reassessment notices issued under Section 12-A were time-barred because the outer limit of eight years from the expiry of the relevant year had already passed. The proviso to Section 12-A(2) did not save the proceedings, as exclusion of limitation applies only where reassessment is made on the assessee or a person intimately connected with earlier proceedings in consequence of a finding, direction, order, or judgment; a Supreme Court ruling in another case did not extend limitation for a stranger to those proceedings, and the interim order in that matter did not justify excluding the intervening period. The reassessment orders and consequential demand notices were quashed.

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Issues: Whether the reassessment notices and orders under Section 12-A were barred by limitation, and whether the proviso to Section 12-A(2) could be invoked on the ground that the reassessment followed the Supreme Court's decision in another case.

Analysis: Section 12-A(1) prescribes an outer limit of eight years from the expiry of the relevant year for reassessment of escaped turnover. The notices were issued well after that period. The proviso to Section 12-A(2) excludes limitation only where the reassessment is made on the assessee or any person in consequence of, or to give effect to, a finding, direction, order, or judgment within the meaning of that provision. The petitioner was neither a party to the earlier litigation nor a person intimately connected with those proceedings. A judgment in another case, by itself, did not extend limitation for a stranger to the earlier proceedings. The interim order in the earlier Supreme Court matter also did not stop the revenue from proceeding with reassessment and therefore did not justify exclusion of the entire intervening period.

Conclusion: The proviso to Section 12-A(2) was inapplicable, and the reassessment proceedings were barred by limitation.

Final Conclusion: The impugned reassessment orders and consequential demand notices were quashed.

Ratio Decidendi: The limitation exclusion for reassessment under the proviso to Section 12-A(2) applies only where the assessee or a person intimately connected with the earlier proceedings is bound by the relevant finding, direction, order, or judgment, and it cannot be invoked merely because a different case declared the law.

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