Defective demand notice timing is curable, and does not invalidate the assessment or later appellate orders.

A demand notice allowing less than thirty days for payment is defective only as to the payment date where the statute requires a minimum thirty-day period, but that defect does not void the assessment or the later appellate and revisional orders. The notice still serves to communicate the assessed demand and the assessee may challenge the assessment once service is effected. The proper cure is issuance of a fresh demand notice fixing a lawful payment period in conformity with the statute.

---

---

Issues: Whether a notice of demand issued with less than thirty days' time for payment after service is invalid, and whether such defect vitiates the assessment or the subsequent appellate and revisional orders.

Analysis: The statutory scheme required the notice of demand to specify a payment date not less than thirty days from the date of service. The notice in question gave a shorter period, so it was defective as to the date fixed for payment. However, the notice served two distinct functions: it conveyed the assessed amount and fixed the payment date. A defect in the latter did not nullify the assessment itself. The defect was curable by issuing a fresh demand notice with a lawful payment period, and the assessee's appeal against the assessment remained maintainable because the notice had been served. The challenge to reopen the assessment after the appellate and revisional orders was rejected, as the defect in the demand notice did not invalidate those orders.

Conclusion: The notice of demand was not void in its entirety and did not vitiate the assessment, appellate order, or revisional order. The defect was confined to the payment date and called only for a fresh modified demand notice.

Ratio Decidendi: A demand notice defective only in the time allowed for payment is curable and does not invalidate the underlying assessment or later appellate and revisional orders; the proper remedy is issuance of a fresh notice in conformity with the statute.

---