Mr. Pathak on behalf of the appellant Company pleaded that even if that be the true interpretation of s. 21 as amended, the >ection could only apply to proceedings which were pending at the date on which the Act was amended, but in law no proceeding was pending because the Judge (Revisions) Sales Tax had no rower to direct after the expiry of the period prescribed under s. 21 a:; it originally stood to make a fresh assessment in respect of the 'ear 1948-49. There are two clear answers to this plea, either of which is sufficient to reject it. The revisional authority had under s. IO: 3) power to make such order as he thought fit Jftercalling for and c::.amining the record of any order made hy an appellate or an a"essing authority and after satisfying himself as to the legality or propriety of such order. Even assuming that the revisional authority came to a conclusion which was erroneous in law, it was still an order which he had jurisdiction to make and that order unless set aside in a proper proceeding could not be ignored on the g:ound of lack of jurisdiction. There was, therefore, a ;J' ocxding pending before the Sales Tax Officer in pursuance of 1~.e direction given by the Judge (Revisions) Sales Tax who had ct:rccted the Sales Tax Officer to make a fresh assessment. Whether in pursuance of this direction, a fresh assessment could be made under s. 21 before it ws amended, need not detain us. We arc concerned with the jurisdiction of the revising authority to make the order that he did under the section as it stood amended, and not with the competence of the assessing authority to pass an order for assessment under the statute before it was amended. The other ground is also equally decisive. By s. 15 of Act 19 of 1956, s. '21 of the Act as amended, must be deemed to have been on the statute book on the date on which the revising authority pJssed his order, and under that amended provision the power of the as\essing authority !o as<ess or re-assess pursuant to an order of the revising authority w:•s not !0st when the period prescribed by ub-s. 2 of s. 21 for c:ssessment or r-a-s"men! expired. Under s. 21. before it was amended. there could be no nrder of assessment cir re-assessment eithec bv !h~ Sal" Ta\ Officer s110 mo•u, or nm5u:mt to the direction of the appellate or revising authority after the c11piry of the period of three years prescribed by the statute, hut under s. 21 as amended, the power may be exercised by the Sales Tax Officer s110 motu within four years for assessment or
