Revenue could tax only if case fell within four corners of Statute, not on legislative intent or substance

Shiv Steels Vs State of Assam & Ors. (Supreme Court of India)

Conclusion: Where assessments were subsequently held invalid as being time-barred under Section 19, Revenue could not revive such invalid assessments by resort to Section 21. Supreme Court held that the Revenue authorities could not impose tax on the basis of legislative intent, substance, or analogy, unless the case strictly fell within the provisions of the statute.

Held: The present appeal arose from the common judgment and order passed by the Gauhati High Court, whereby th

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