Sales tax demand orders quashed where no return disapproval or final assessment existed, and administrative direction exceeded authority.

Sales tax demand orders could not be sustained where the return had not been disapproved and no final assessment had been completed. The assessing authority was required to act independently within its quasi-judicial role, and the Commissioner of Commercial Taxes could not direct issuance of demands through administrative interference. The demand orders were therefore quashed, while the authorities were left free to complete final assessment in accordance with law and adjust any excess payment against future liability.

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Issues: Whether the sales tax demand orders could be sustained when the return had not been disapproved or final assessment made, and whether the Commissioner of Commercial Taxes could direct the assessing authorities to make such demands.

Analysis: The orders were issued before any disapproval of the return or completion of final assessment. The demand was made only in pursuance of the Commissioner's direction, although the assessing authority was required to act independently and within the limits of its quasi-judicial function. Administrative interference in that process was not authorised.

Conclusion: The demand orders were not sustainable and were quashed. The authorities were left free to make final assessment and determine liability in accordance with law, with excess payment to be adjusted against future liability.

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