Reasonable time applies to revisional power, and unexplained decade-long delay makes the proceeding unsustainable.

A revisional power under section 34 of the Agricultural Income-tax Act, 1950, even without an express limitation period, must be exercised within a reasonable time. Where proceedings are initiated after more than ten years, exceptional and extenuating circumstances must be shown on record; absent such material, the delay is fatal. The later insertion of a four-year limit in section 76 of the Kerala Agricultural Income-tax Act, 1991, reinforced that the power was never intended to remain open indefinitely. The initiation of revision after the long delay was therefore barred by limitation and unsustainable.

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Issues: Whether revisional proceedings initiated under section 34 of the Agricultural Income-tax Act, 1950, after more than ten years from the original assessment were barred by limitation or otherwise could not be sustained.

Analysis: The revisional power under section 34, though not subject to an express statutory period of limitation, had to be exercised within a reasonable time. A delay of more than ten years required exceptional and extenuating circumstances, which had to be demonstrated on record. No material was shown to justify the prolonged delay. The later enactment in section 76 of the Kerala Agricultural Income-tax Act, 1991, which imposed an express four-year limit, reinforced the legislative recognition that such power could not remain indefinitely open.

Conclusion: The initiation of proceedings after the lapse of more than ten years was barred by limitation and could not be sustained. The answer was in favour of the assessee and against the Department.

Ratio Decidendi: Where a revisional power is conferred without an express limitation period, it must still be exercised and concluded within a reasonable time, and unexplained delay of extraordinary length renders the exercise invalid.

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