COMMERCIAL MOTORS LTD. vs COMMISSIONER OF TRADE TAX U.P., LUCKNOW & ORS.

The Supreme Court addressed the reopening of assessments under Section 21(2) of the U.P. Trade Tax Act, 1948, holding that the amendment to the section allowing for reopening assessments has retrospective effect. The Court ruled that the proceedings initiated after the six-year limitation period were valid due to the amendment, thus allowing the revenue to reassess the tax liability of the appellant. The Court affirmed the High Court's decision to allow the reopening of the assessment despite the appellant's claims of limitation and prior examination of accounts.