THE COMMERCIAL TAX OFFICER & ORS. vs M/S. BISWANATH JHUNJHUNWALLA & ANR.

The Supreme Court upheld the Calcutta High Court's decision that the reopening of assessments under the Bengal Finance [Sales Tax] Act, 1941, was barred by the unamended provisions of Rule 80(5)(ii), which allowed revision only within four years. The Court noted that the amendment to extend this period to six years could not be applied retrospectively to assessments completed before the amendment. Consequently, the notices issued by the Commercial Tax authorities were deemed invalid, affirming the High Court's ruling.