https://www.taxtmi.com/caselaws?id=778504 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. en-us Thu, 11 Sep 2025 00:00:00 +0530 Thu, 18 Sep 2025 08:30:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778504 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. Case-Laws VAT / Sales Tax Thu, 11 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778504