DEPUTY COMMISSIONER OF COMMERCIAL TAXES vs H.R. SRI RAMULU

The Supreme Court held that for the computation of the four-year period under Section 21(3) of the Mysore Sales Tax Act, 1957, the starting point is the order made under Section 12A, not the initial assessment order. The Court reasoned that once an assessment is reopened, the initial order ceases to be operative, and the reassessment order substitutes the initial order. Consequently, the High Court's ruling that the revisions were beyond the limitation period was overturned, affirming the validity of the reassessment orders made under Section 12A.