Proof of firm dissolution must be timely and evidenced before assessment; writ interference is limited to perverse findings.

Proof that a firm had dissolved before an assessment date must be supported by timely and clear evidence, including statutory intimation of dissolution where required. Here, the long continuation of proceedings without prompt notice to the assessing authority, together with failure to give the dissolution intimation within thirty days under section 16 of the Punjab General Sales Tax Act, created serious doubt about the alleged dissolution. The text also notes that writ interference with such factual findings is limited to cases where the finding lacks evidence, rests on irrelevant material, or is perverse. On that basis, no ground was made out to quash the assessment order.

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Issues: Whether the appellant-firm had proved that it stood dissolved before the date of the assessment order and, if so, whether the assessment could be quashed.

Analysis: The appellant asserted dissolution before the assessment date, but the surrounding circumstances created serious doubt about that assertion. Hearings continued for a long period without any clear intimation to the assessing authority that the firm had dissolved, and the statutory intimation of dissolution required under section 16 of the Punjab General Sales Tax Act was not given within thirty days of the alleged dissolution. In writ jurisdiction, interference with such a factual finding is limited and is justified only where the finding is unsupported by evidence, based on irrelevant material, or is perverse.

Conclusion: The appellant failed to prove dissolution before the assessment date, and no ground was made out for interference with the assessment order.

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