1971 (2) TMI 90

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..... 64-65. The Sales Tax Officer, Tellicherry, issued a pre-assessment notice to the assessee for the years 1961-62, 1962-63, 1963-64 and 1964-65 on 18th March, 1965, under section 12 of the General Sales Tax Act, 1125. The notice directed the assessee to file its objections to the proposals contained in the notice within 3 days. The assessee's case is that he received the notice only on 27th March, 1 .....

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..... ssessment notice had been received by him only on 27th March, 1965, and by the time he applied for extension of time he came to know that the assessment had been made on a best of judgment basis on 27th March, 1965, itself. It is well-settled that in making a best judgment assessment the assessing authority discharges a quasi-judicial function and that a reasonable opportunity should be provided t .....

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