Eligibility certificate in force bars assessment for the covered period until lawful cancellation.

An assessment could not be sustained for a period covered by an eligibility certificate that remained operative and had not been cancelled by the competent authority. Because the Commissioner declined to cancel the certificate, the assessing authority lacked a valid basis to assess the period governed by that certificate. The assessment order was therefore held unsustainable and was quashed.

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Issues: Whether an assessment order could be sustained for a period covered by an eligibility certificate that had not been cancelled by the competent authority.

Analysis: The eligibility certificate remained operative until cancelled by the competent authority. Since the Commissioner had declined to cancel the certificate, the assessing authority could not make a valid assessment for the period covered by that certificate.

Conclusion: The assessment order was not sustainable and was quashed.

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