ORDER G. C. BHARUKA, J. - The present revision petition relates to assessment made under the Central Sales Tax Act, 1956 (in short, "the Central Act") for the assessment year 1981-82. The original assessment against the petitioner was completed on June 13, 1984. Subsequently, pursuant to certain seizures in relation to the business transactions of the petitioner, it was subjected to reassessment proceeding which culminated in a reassessment order dated December 28, 1988. The only question raised on behalf of the petitioner is that keeping in view the provisions of section 12A of the Karnataka Sales Tax Act, 1957 (in short, "the State Act") the order of reassessment is barred by limitation. 2. Section 9(2) of the Central Act, inter alia, empowers the authorities under the State Act to assess or reassess a dealer in relation to Central sales tax as per the provisions of the State Act. Section 12A of the State Act provides for reassessment and also prescribes the time limitation for the same till July 31, 1985; and the period of limitation so provided was 5 years from the expiry of the year to which the tax related. With effect from August 1, 1985, by Act 27 of 1985, the period of 5 years was substituted by 10 years. Again from April 1, 1988, by Act 15 of 1988, it was reduced to 8 years. 3. In the present case it is not in dispute that the assessment as made on December 28, 1988 is well within the period of limitation as per the provision of section 12A as it stood at the time of passing of the said order. But the contention of Sri B. P. Gandhi, learned counsel appearing for the petitioner is that the limitation should be computed keeping in view the law either as it existed at the time of filing of the return or as it existed at the time of completion of the original assessment. According to him, since in either of these two situations, the period of limitation was five years from the end of the relevant year, i.e., 1981-82, the time for completion of reassessment should be held to have expired on March 31, 1987. Therefore, according to him, reassessment as made on December 28, 1988 is barred by limitation. 4. According to him, since in either of these two situations, the period of limitation was five years from the end of the relevant year, i.e., 1981-82, the time for completion of reassessment should be held to have expired on March 31, 1987. Therefore, according to him, reassessment as made on December 28, 1988 is barred by limitation. 4. In the case of Mahaveer Drug House v. Assistant Commissioner of Commercial Taxes [1991] 82 STC 388, para 4, which has been noticed with approval by us in the case of Combined Industrial Limited v. State of Karnataka [1999] 112 STC 225 (Kar); ILR 1996 Kar 822, it has been held by this Court that : "So long there is a possibility of reopening any assessment for any reason and no immunity has accrued to the assessee, the existing period of limitation may be enlarged by legislation. But once there is immunity, unless the Legislature amends the law retrospectively or declares any provision as applicable to the concluded proceedings also by clear and specific words, it is not possible to read into those provisions a power enabling the assessing authorities to undo what has become final." 5. In the present, admittedly, the period of limitation was enlarged by the Legislature before any immunity could have been validly claimed by the petitioner-assessee. It cannot be disputed that it was competent on the part of the Legislature to do so. 6. In this view of the matter, the plea raised by the petitioner that the proceedings had become barred by limitation in the sense that the respondent-assessing authority had lost the jurisdiction to make reassessment for the assessment year 1981-82, cannot be sustained in law and is accordingly rejected. 7. The revision petition is accordingly dismissed. Petition dismissed.