Reassessment notice must specify the assessment year, or it is jurisdictionally invalid and cannot sustain reopening proceedings.

A reassessment notice must clearly identify the assessment year sought to be reopened, because that particular is a jurisdictional requirement and not a curable irregularity. Where the notice omits the relevant assessment year, the defect goes to the root of the authority's power to initiate reassessment proceedings, rendering the notice invalid. The HC therefore treated the omission as fatal and found no need to separately examine the competency of the issuing authority.

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Issues: Whether a notice issued for reopening assessment is invalid when it does not specify the assessment year to which it relates.

Analysis: A notice initiating reassessment must clearly and particularly identify the assessment year sought to be reopened. The omission of that essential particulars is not a mere irregularity but goes to the root of the authority's jurisdiction. Since neither of the notices mentioned the relevant assessment year, the defect was fatal. In view of this conclusion, no separate adjudication on the competency of the issuing authority was necessary.

Conclusion: The notice was jurisdiction and invalid for want of specification of the assessment year.

Ratio Decidendi: A reassessment notice is a condition precedent to valid reassessment proceedings, and its failure to specify the assessment year deprives the authority of jurisdiction.

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