Jurisdiction to reopen assessments upheld where notices disclosed a prima facie basis for Rule 10A and merits were left open.

Jurisdiction to reopen assessments was challenged on the ground that the show-cause notices were time-barred and fell only within Rule 10, but the Court found that the materials referred to in the notices disclosed a prima facie basis to invoke Rule 10A. The writ petition was confined to that jurisdictional issue, and the Court declined to examine the merits of the valuation dispute or the alleged flow-back of discounts, leaving those matters to departmental adjudication. The challenge to the notices therefore failed, and the notices were upheld against the assessee.

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Issues: Whether the show-cause notices were liable to be quashed on the ground that the Department had no jurisdiction to reopen the assessments and that the notices were barred by limitation.

Analysis: The writ petition was confined to the question of jurisdiction. The Court found that, on the materials referred to in the notices, the Department had made out a prima facie case to invoke Rule 10A. The petitioner's challenge that the notices were time-barred and that the matter fell only within Rule 10 was not accepted at this stage. The Court also declined to express any opinion on the merits of the valuation dispute or the alleged flow-back of discounts, leaving those matters to the departmental adjudication.

Conclusion: The challenge to the notices failed, and the notices were upheld against the assessee.

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