1991 (1) TMI 416

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....e Act'), the assessments were to be completed on or before 7th April, 1982. The assessing authority moved an application for extension of time under the second proviso to section 10B(1)(iv) of the Act for completion of the assessment and Additional Commissioner, Commercial Taxes, Jaipur, vide his order No. F. 16/3/72/Tax/CCT/82/PT granted extension of time for completion of the assessment. On receipt of the order for extension of time, the assessing authority fixed the date of hearing for completion of the assessment proceeding. In pursuance of the notice issued by the assessing authority, the representatives of the assessee-firm appeared before him. The representatives were informed about the extension of time granted by the Additional C....

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....ent shall be made (i) to (iv)........................ Provided that......... Provided further that the Commissioner may, for reasons to be recorded in writing, extend in any particular case, the period specified in this sub-section by a period not exceeding six months. (2)............ (i).............. Provided that the Commissioner may, for reasons to be recorded in writing in any particular case extend the period specified in this clause by a further period not exceeding six months." Admittedly, in this case, extension was granted by the Additional Commissioner after limitation had expired and that no reasons for the same had been recorded. It was a stereo type order which does not give any reason for extension and only records it....