Recorded reasons for reopening assessment are mandatory; a blank, unsigned notice cannot validly found revision proceedings.

Revision proceedings under section 35 of the Madras Agricultural Income-tax Act, 1955 were jurisdictionally defective because the notice was a blank printed form, unsigned, unparticularised, and unsupported by any recorded reason showing that the officer had reason to believe income had escaped assessment. The statutory precondition for reopening or revising the assessment was therefore not satisfied, and there was no valid commencement of proceedings. The assessee's alleged participation in the enquiry could not cure the defect, since jurisdiction had not been properly invoked. The revision and reassessment were accordingly set aside for want of proper initiation and service of notice.

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Issues: Whether the revision proceedings under section 35 of the Madras Agricultural Income-tax Act, 1955 were valid when the assessee had not been properly served with notice and the initiation of proceedings was unsupported by any recorded reason.

Analysis: The notice relied upon was found to be a blank printed form, not filled up, not signed, and not showing any reason for invoking section 35. The statutory precondition for action under section 35 was that the Agricultural Income-tax Officer must have reason to believe that income had escaped assessment, and the record did not disclose any valid initiation of proceedings. The assessee's alleged participation in an enquiry could not cure the defect, because there was no proper commencement of proceedings capable of attracting section 35 jurisdiction. The Commissioner's assumption that the proceedings were regularly initiated was therefore based on a patent error and amounted to an irregular exercise of jurisdiction.

Conclusion: The notice and the resulting revision proceedings under section 35 were invalid, and the challenge to the reassessment succeeded in favour of the assessee.

Final Conclusion: The assessment revision was set aside for want of proper initiation and service of notice, with no adjudication on the merits of the reassessment.

Ratio Decidendi: Where a statute makes recorded grounds a condition precedent for reopening or revising an assessment, proceedings initiated on a blank or unparticularised notice without disclosed reasons are jurisdictionally defective and cannot be validated by subsequent participation.

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