Judgment

D.P. Wadhwa, J.-Leave granted.

2. In both these appeals which are against two separate judgments of the same Division Bench of the Allahabad High Court, a common question of law arises. It is that in the circumstances could a completed assessment under the U.P. Sales Tax Law be re-opened after the pre­scribed period when that period was enlarged by amending the law.

3. Facts are similar.

4. In the appeal of Lohia Machines Limited (arising out of SLP(C) No. 11015 of 1997) assessment for the year 1985-86 under the UP Trade Tax Act, 1948 (for short ‘the Act’) was completed on November 27, 1989. The Act is also called the U.P. Sales Tax Act. In the appeal of Jyoti Traders (arising out of SLP (C) No. 8866 of 1997) assessment for the year 1985-86 was completed on February 28, 1990. Period for assessment or reassessment, which is four years under Section 21 of the Act, for the assessment year 1985-86 expired, on March 31, 1990.

5. The Act was extensively amended by the U.P. Sales Tax (Amendment and Validation) Act, 1991. The amending Act received the assent of the Governor of Uttar Pradesh on August 19, 1991. Different dates were prescribed for coming into force of various provisions