Retrospective validation of limitation extension upheld, with no notice or communication required and no prejudice from naming error.

Section 10-B limitation extensions were treated as valid where section 10-BB retrospectively protected assessments made within the extended period, even though no notice was given and reasons were not recorded before the extension. The absence of communication of the extension order to the assessee did not invalidate the assessment, because the order was an internal matter between the Commissioner and the assessing authority and no prior notice was required. A defect in the assessee's name also caused no prejudice, as the assessment and appellate orders sufficiently identified the company. The assessment was upheld and the Revenue succeeded.

---

---

Issues: Whether the assessment orders were invalid because the Commissioner's order extending limitation by six months under section 10-B was made without notice, without communication, without recording reasons, and with an alleged defect in the assessee's name, and whether section 10-BB retrospectively validated such assessments.

Analysis: The extension of limitation granted by the Commissioner was held to be protected by section 10-BB, which validated assessments made during the extended period even where no notice had been given and reasons had not been recorded before extending limitation, so long as the validation fell within the statutory retrospectivity. The Court further held that the absence of communication of the extension order did not vitiate the assessment, since the order was an internal matter between the Commissioner and the assessing authority and no notice to the assessee was required. The alleged omission in the correct name of the assessee was also found to be without prejudice, because the assessment and appellate orders sufficiently identified the respondent-company and no legal injury was shown.

Conclusion: The assessment was valid and the objections to the extension order failed; the revision petitions were allowed in favour of the Revenue.

---