Reasonable time in tax assessments: prolonged unexplained delay after notice can invalidate assessments for unfair and arbitrary adjudication.

A taxing assessment initiated by notice within time must still be completed within a reasonable period, and prolonged unexplained inaction can render the assessment vulnerable to quashing. The HC relied on prior binding authority to hold that Rule 25 does not permit proceedings to remain pending indefinitely after the dealer's response; such delay offends fairness and non-arbitrariness and causes prejudice. Applying that principle, assessment orders passed nearly a decade after the Form-H notice were unsustainable and were set aside for unreasonable and unjustified delay.

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Issues: Whether assessment orders passed nearly 10 years after issuance of the Form-H notice were liable to be quashed for breach of the mandate of Rule 25 and for unreasonable delay in completing the assessment.

Analysis: The assessment proceedings had remained pending for an inordinate period after issuance of the notice and the dealer's response. The Court relied on the earlier binding decision on the same issue, which had held that though the rule may speak to initiation within time, the assessment cannot be kept pending indefinitely and must be concluded within a reasonable period. The Court also noted that prolonged inaction in adjudication causes prejudice and offends fairness and non-arbitrariness in administrative action.

Conclusion: The assessment orders were held to be unsustainable and were quashed as having been passed after an unreasonable and unjustified delay.

Final Conclusion: The petitions succeeded and the impugned assessments were set aside on the ground of delayed adjudication beyond a reasonable period.

Ratio Decidendi: Where a taxing assessment is initiated by notice within time, the authority must still complete the adjudication within a reasonable period; an unexplained delay of about a decade renders the assessment vulnerable to quashing for unreasonableness and prejudice.

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