The problem is that strtok() won't tell you when a token isn't present, so you need some extra logic to identify tokens either by special characteristics or by expected position. Comments are easy because they're always led by a semicolon, but the others can be tricky. For example, if both the label and instruction can be any string, how do you know if you got a label but no instruction or an instruction but no label?
You explained what you're trying to do quite nicely, but that wasn't what I asked for. I asked for details about the assembly format. I hope that your instructor didn't invent something ambiguous that's difficult to parse, because that would just be cruel.