Unsigned show cause notice cannot sustain proceedings where jurisdiction never validly attached.

Proceedings founded on an unsigned show cause notice were held to have no legal efficacy because initiation of action must be under authority of law. The defect was foundational and could not be cured by the assessee's participation, nor could it confer jurisdiction on the authorities. Orders passed on the basis of such a notice could not stand, and the proceedings were treated as ab initio void.

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Issues: Whether proceedings founded on an unsigned show cause notice were valid and capable of sustaining the orders passed thereon.

Analysis: The notice initiating the proceedings was unsigned and was treated as having no legal efficacy. A proceeding must be initiated under authority of law, and participation by the party could not cure the foundational defect or confer jurisdiction on the authorities. Orders passed on the basis of such a notice could not stand.

Conclusion: The proceedings were ab initio void and the appeal was allowed in favour of the assessee.

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