STATE OF ASSAM & ANR. vs D.C. CHOUDHURI & ORS.

The Supreme Court held that under the Assam Agricultural Income-tax Act, 1939, the publication of a general notice under Section 19(1) does not initiate assessment proceedings unless the assessee files a return. The Court ruled that without an individual notice under Section 19(2) or initiation of proceedings under Section 30 within three years, the assessment made on a best judgment basis under Section 20(4) is invalid. Consequently, the assessment orders were quashed as no proper procedure was followed.