Suo motu revision after expiry of reassessment limits requires recorded reasons showing bona fide exercise within a reasonable time.

A suo motu revisional power exercised after the ordinary periods for reopening or rectification had expired must be supported by cogent reasons showing why the action was taken within a reasonable time. Where assessments had attained finality, the revisional authority was required to apply its mind to the relevant facts, indicate bona fide justification, and identify any exceptional or supervening circumstances explaining the delay. In the absence of such recorded reasons, the revisional order was treated as unsustainable and the matter required reconsideration in accordance with law.

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Issues: Whether the Commissioner could exercise suo motu revisional power after the normal period for reopening or rectification of the assessments had expired, without recording cogent reasons showing that the delay was justified.

Analysis: The assessments had attained finality, and the normal periods for reopening under section 35 and rectifying under section 36 had long expired before the revisional notices were issued. In such a situation, exercise of revisional power under section 34 required the Commissioner to apply his mind to the relevant facts and circumstances and record why the action was taken after the ordinary period, with reference to reasonable time, bona fide exercise of power, and any exceptional or supervening circumstances justifying the delay. The revisional order did not disclose any such consideration or basis.

Conclusion: The revisional order was unsustainable for want of reasons showing that the power under section 34 had been exercised within a reasonable period, and the matter had to be reconsidered afresh in accordance with law.

Ratio Decidendi: Where a final assessment is sought to be reopened in suo motu revision after the ordinary statutory periods for reopening or rectification have expired, the revisional authority must record cogent and sufficient reasons demonstrating that the power was exercised bona fide and within a reasonable time.

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