Mandatory reasons and hearing are required before extending assessment time once limitation has expired.

Extension of the assessment period under section 10B of the Rajasthan Sales Tax Act was held invalid where it was granted after the time limit had expired without notice to the assessee, without an opportunity of hearing, and without recorded reasons. The court treated the requirement to record reasons as mandatory and found that a stereotype, non-speaking order could not revive time-barred assessment proceedings. Because the absence of hearing and reasons went to the root of jurisdiction, the extension order was struck down and the assessment proceedings founded on it were vitiated.

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Issues: Whether extension of time for completion of assessment under section 10B of the Rajasthan Sales Tax Act, 1954 was valid when granted without notice and opportunity of hearing to the assessee and without recording reasons.

Analysis: The provision empowered extension only for reasons to be recorded in writing, and the order in question was a stereotype order containing no reasons. The Court held that where a time limit for assessment had expired, extension could not be granted validly without hearing the assessee, and that recording reasons was mandatory. The absence of opportunity and reasons went to the root of the jurisdiction exercised for reviving the time-barred assessment proceedings.

Conclusion: The extension order was invalid, and the assessment proceedings founded on it were vitiated.

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