Reasonable time limits govern suo motu revision of final assessments; extraordinary delay without justification invalidates proceedings.

Suo motu revisional power under section 34 of the Kerala Agricultural Income-tax Act must be exercised within a reasonable time when it affects concluded assessments. Here, the assessments had long attained finality, and the revisional action was initiated nearly 15 years later without any cogent justification, supervening circumstance, or material explaining the delay. The court held that the statutory scheme did not permit such open-ended revision after the normal periods for reassessment and rectification had expired, so the proceedings were barred, unauthorised, and without jurisdiction.

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Issues: Whether the suo motu revisional power under section 34 of the Kerala Agricultural Income-tax Act could be exercised after a long lapse of time and whether the proceedings initiated nearly 15 years after the assessments were made were sustainable.

Analysis: The assessments had attained finality long before the revisional action was taken. The statutory scheme contemplated reopening of assessments within the normal periods prescribed for reassessment and rectification, and the exercise of suo motu revisional power after those periods required cogent and sufficient justification. No reason or material was shown to explain the extraordinary delay or to establish any supervening circumstance preventing earlier action. In these circumstances, the revisional authority's view that there was no time-limit could not be accepted, and the power was not exercised within a reasonable period.

Conclusion: The proceedings under section 34 were not initiated within a reasonable time and were barred, unauthorised, and without jurisdiction; the reference was answered in the affirmative in favour of the assessee.

Ratio Decidendi: A suo motu revisional power affecting a concluded assessment must be exercised bona fide within a reasonable time, and in the absence of cogent justification for extraordinary delay, the revisional proceedings are invalid.

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