Company notice service and saved-proceeding revision limits upheld, preserving assessment jurisdiction and rejecting further revision.

Assessment notices issued in a company's name and accepted by the director in charge were not invalid merely because the principal officer was not named individually; service on the company through its authorised officer was sufficient, so the assessments were not without jurisdiction. A revision under the 1991 Act was not maintainable against orders passed under the 1950 Act because the repeal-and-saving framework kept such proceedings governed by the old Act, and the successor revisional provision did not create an additional remedy. Procedural defects in the revision papers, including missing assessment orders and demand notices, also remained uncured.

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Issues: (i) Whether assessment notices and assessment orders served in the name of the company, and accepted by the director in charge, were invalid for want of service on the principal officer so as to render the assessments without jurisdiction; (ii) Whether the revision applications filed before the Commissioner under the 1991 Act against orders passed under the 1950 Act were maintainable.

Issue (i): Whether assessment notices and assessment orders served in the name of the company, and accepted by the director in charge, were invalid for want of service on the principal officer so as to render the assessments without jurisdiction.

Analysis: The relevant provisions contemplated service on the principal officer of a company, but the notices were issued in the name of the company, received by the director in charge, and acted upon by the company through appeals and revisions. The earlier decision relied on by the assessee was distinguished because there the notice was not shown to have been served on the entity assessed, whereas here the service was in the company's name and accepted by its principal officer as agent. On these facts, the absence of the principal officer's individual name on the notice did not create a jurisdictional infirmity.

Conclusion: The notices and assessment orders were not invalid for want of service on the principal officer, and the assessments were not without jurisdiction.

Issue (ii): Whether the revision applications filed before the Commissioner under the 1991 Act against orders passed under the 1950 Act were maintainable.

Analysis: The orders under challenge had been passed by the Deputy Commissioner exercising powers under the 1950 Act. In view of the repeal-and-saving provision, pending proceedings were to be continued under the old Act, and the new revisional provision did not create a further revision against such orders. In addition, the applications suffered from procedural defects, including the absence of the requisite assessment orders and demand notices, and those defects were not cured.

Conclusion: The revision applications were not maintainable.

Final Conclusion: The challenge to the assessments failed both on jurisdiction and on maintainability, and the tax revision was rejected in full.

Ratio Decidendi: Where a company receives assessment notices in its own name through its principal officer and acts upon them, the assessments are not rendered without jurisdiction merely because the notice is not addressed in the officer's individual name; a further revision under a successor statute is unavailable when the impugned order is one saved and governed by the repealed statute.

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