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31. Twin cardinal principals of Public law are that a public functionary exercising quasi-judicial authority must always keep himself within the jurisdiction assigned to him and the other is that he must always exercise his powers strictly in accordance with law. If the assessing officer wants to exercise his jurisdiction under section 147/148, what, in our view, should be seen in that case is whether all the ingredients of section 147/148 are satisfied. If they are satisfied his action has to he upheld being in consonance with the judicial principle that power must be exercised in accordance with law. Likewise, if the assessing officer wants to exercise the powers under section 143(2)/143(3), he must satisfy all the ingredients prescribed for the exercise of that power. Exercise of power by a public functionary cannot be defeated so long as he satisfies all the requisites statutorily laid down for the exercise of that power. There is a long line of judicial authorities supporting the aforesaid view.

13. In Bhaimagar University v. Palitana Sugar Mill (P.) Ltd. (2003) 2 SCC 111, 125-26, the Honble Supreme Court has explained the law, with regard to the nature of time provision, in paragraph 42 of the judgment thus. We are not oblivious of the law that when a public functionary is required to do a certain thing within a specified time, the same is ordinarily directory but is equally well-settled that when consequence for inaction on the part of the statutory authorities within such specified time is expressly provided, it must be held to be imperative."