Valid notice as a condition precedent bars reassessment where the notice was absent, late, or fundamentally invalid.

A notice in the prescribed form under section 12 was treated as a condition precedent to valid reassessment, so reassessment could not proceed where no effective notice was issued within the prescribed time or the notice was fundamentally invalid. Section 19A was held to have only limited curative scope: it can save defects of form with substantial conformity, but it cannot validate a complete absence of a valid notice. The reasoning was aligned with the analogous principle under section 292-B of the Income-tax Act, which does not cure the non-existence of a valid notice. The reassessment proceedings were therefore barred and the defect was not curable under section 19A.

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Issues: Whether reassessment proceedings could be sustained when the notice under section 12 was not issued in the prescribed form or within limitation, and whether section 19A could cure the defect.

Analysis: The notice in the prescribed form under section 12 was treated as a condition precedent to a valid reassessment. Section 19A was held to have a limited curative operation and to apply only to defects of form where there is substantial conformity with the Act. It could not validate a case where no effective notice under section 12 had been issued within the prescribed time, or where the notice was otherwise fundamentally invalid. The reasoning was supported by the analogous scope of section 292-B of the Income-tax Act, which does not cure the complete absence of a valid notice.

Conclusion: The reassessment proceedings were barred and the defect in notice could not be cured by section 19A.

Final Conclusion: The revisions failed because the reassessment was not validly initiated by a timely and proper notice under the governing sales tax provision.

Ratio Decidendi: Where issuance of a notice in the prescribed form is a condition precedent to reassessment, a fundamental absence or invalidity of such notice cannot be cured by a provision that saves only defects of form.

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