Best judgment assessment requires mandatory notice and lawful reassessment steps under the Assam Agricultural Income-tax Act.

Assessment under the Assam Agricultural Income-tax Act, 1939 could not validly be completed by best judgment under section 20(4) where no individual notice under section 19(2) had been served and no lawful reassessment proceedings under section 30 were taken within time. The statutory scheme treated the general notice, individual notice, and escaped-income reassessment as distinct procedural steps, and section 20(4) was not a substitute for those mandatory requirements. The assessee's statutory right under section 43(2)(a), together with the corresponding principles under the Indian Income-tax Act, 1922, supported this construction. Assessments made without compliance with section 19(2) or valid recourse to section 30 were therefore unsustainable.

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Issues: Whether, in the absence of individual notice under section 19(2) of the Assam Agricultural Income-tax Act, 1939, assessment could validly be completed under section 20(4) without resort to proceedings under section 30, and whether such assessments were barred by limitation.

Analysis: The statutory scheme distinguished between a general notice under section 19(1), an individual notice under section 19(2), and reassessment in cases of escaped income under section 30. A best judgment assessment under section 20(4) could not be invoked as a substitute for the mandatory procedural steps where no return had been filed pursuant to the general notice. The scheme of the Act, including the assessee's statutory right under section 43(2)(a), showed that assessment proceedings were initiated only by service of notice under section 19(2) or by proceedings under section 30 within the prescribed period. The corresponding provisions of the Indian Income-tax Act, 1922, and the principles governing escaped assessment supported this view.

Conclusion: The assessments made without compliance with section 19(2) or valid recourse to section 30 were unsustainable, and the challenge by the assessees succeeded.

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