Limitation in sales tax reassessment cannot be revived by later sanction where the original assessment was already time-barred.

Section 19 of the Assam General Sales Tax Act, 1993 fixes the time limits for assessment and reassessment, while Section 21 is a special enabling provision that applies only where no assessment has been made within those limits and prior sanction of the Commissioner is obtained. Where the original assessments had already been held time-barred under Section 19, a later sanction could not revive the proceedings or bring them within Section 21. The two provisions operate in distinct fields, and the revenue had to satisfy the statute strictly. Section 21 was therefore inapplicable, and the reassessment could not be sustained.

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Issues: Whether reassessment, after the original assessments were held time-barred under Section 19 of the Assam General Sales Tax Act, 1993, could be sustained by invoking Section 21 of the Act on the basis of subsequent sanction from the Commissioner.

Analysis: Section 19 prescribes the time limits for assessment and reassessment, while Section 21 is a special enabling provision that applies where no assessment has been made within the time limits specified in Section 19 and permits assessment within four years from expiry of the limitation period with prior sanction of the Commissioner. The original assessments for the relevant years had already been invalidated as time-barred under Section 19. In that situation, the later sanction could not revive the matter or transform it into a case covered by Section 21. The two provisions operate in distinct fields, and the revenue was required to bring the case strictly within the four corners of the statute.

Conclusion: Section 21 was inapplicable, and the reassessment could not be sustained after the original assessments were held time-barred.

Ratio Decidendi: In fiscal statutes, tax liability must arise strictly within the statutory framework, and a special limitation-relaxing provision cannot be used to revive proceedings already found barred unless the case squarely falls within that provision.

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