Reasonable-time limits on revisional power require cogent reasons, and a stale reopening order without justification is unsustainable.

Revisional power to reopen concluded assessments must be exercised bona fide within a reasonable time and supported by cogent reasons explaining the delay. The Kerala High Court noted that earlier assessments had attained finality and that a later rectification did not remove the need to justify exercise of section 34 revisional jurisdiction after a long lapse. Because the revisional order gave no reasons for the delay or any exceptional circumstance warranting reopening, the order was held infirm and not in accordance with law, and the matter was remitted for fresh consideration on the governing principles of reasonable time.

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Issues: Whether the revisional power under section 34 could be exercised after a long lapse of time without cogent reasons, and whether the revision order was sustainable.

Analysis: The assessments had attained finality years earlier, and the later rectification under section 36 did not dispense with the need to justify the exercise of revisional power under section 34. The Court applied the principle that revisional jurisdiction, though not controlled by a rigid limitation period, must be exercised bona fide, within a reasonable time, and on demonstrable reasons showing why the matter was not taken up earlier. The revisional order contained no reasons explaining the delay or the exceptional circumstances required to sustain reopening after such a long interval.

Conclusion: The revision order was found infirm and not in accordance with law. The matter was sent back for fresh consideration in the light of the governing principles on reasonable time.

Final Conclusion: The revisional proceedings were not finally upheld on the existing order, and the assessing authority was directed to reconsider the matter afresh within the specified time.

Ratio Decidendi: Revisional powers to reopen concluded assessments must be exercised within a reasonable time and supported by cogent reasons explaining the delay; a stale revision order passed without such reasons is unsustainable.

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