Statutory validation of extended-limitation assessments upheld, with lack of notice or recorded reasons not defeating the assessment.

Section 10-BB of the Rajasthan Sales Tax Act validated assessments made during the extended limitation period even where no notice was given to the assessee and no reasons were recorded for extension. The provision expressly treated such assessments and related acts as valid and effective, while preserving challenges on grounds other than limitation extension. On that statutory basis, the Tribunal's view that the assessment was void for want of notice and reasons could not stand, and its order was quashed. The assessee remained free to pursue other merits-based objections before the Tribunal.

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Issues: Whether section 10-BB of the Rajasthan Sales Tax Act, 1954 validated assessments made during the extended period of limitation without notice to the assessee and without recorded reasons, and whether the Tribunal's order setting aside the assessment could stand.

Analysis: The assessment had been set aside by the Tribunal on the footing that the Commissioner's order extending limitation was illegal for want of notice and reasons. Section 10-BB was subsequently inserted to validate assessments made during the extended period, notwithstanding the absence of notice to the assessee or recorded reasons before extension. The provision expressly declared such assessments, and the acts done in connection with them, to be valid and effective, while preserving the right to challenge assessments on grounds other than limitation extension. In view of this statutory validation, the Tribunal's conclusion that the assessment was void could not be sustained.

Conclusion: The challenge to the assessment on the ground of extension of limitation failed, and the Tribunal's order was quashed. The assessee was left free to pursue other merits-based objections before the Tribunal.

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