Voidable assessment orders and limitation barred later challenge to reassessment notices after acquiescence in earlier proceedings.

An assessment order made by a competent authority is not void merely because of an alleged irregularity in notice; at most it is voidable and must be challenged promptly in the proper forum. Where the taxpayer received the earlier notices and orders, did not assail them within limitation, and acquiesced in the proceedings, the taxpayer cannot later invalidate consequential reassessment steps by attacking only the subsequent notice. The challenge to the notices and proposed reassessment therefore failed, and no relief was granted.

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Issues: Whether the petitioner was entitled to quash the notices and the proposed reassessment proceedings on the ground that the earlier reopening and review orders were void and that the subsequent proceedings were jurisdiction and time-barred.

Analysis: The petitioner had received the earlier notices and orders but did not challenge them within the prescribed time. The Tribunal held that any alleged irregularity in the earlier notices did not render the orders void ab initio, because the assessing authorities had jurisdiction to make those orders. At best, the orders were voidable and had to be challenged promptly in the proper forum. Since the petitioner remained silent, acquiesced in the proceedings, and allowed limitation to expire, the petitioner could not later reopen the validity of the earlier orders by attacking only the subsequent reassessment notice.

Conclusion: The challenge to the notices and proposed reassessment proceedings failed, and the petition was not entitled to relief.

Ratio Decidendi: An assessment order passed by a competent authority is not void merely because of an alleged irregularity in notice; such an order is only voidable and must be challenged within limitation, failing which the party cannot later impeach consequential proceedings on the same ground.

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