Show-cause notices must be answered first, with objections heard on merits and recovery stayed until fresh orders are passed.

Where impugned communications operate as show-cause notices, the aggrieved party must be allowed to file objections, including grounds raised in revision, before the assessing authority. The authority must consider those objections and pass a fresh order on merits and in accordance with law. Until such decision is made, coercive recovery proceedings based on the notices are to remain in abeyance. The matter was therefore remitted for statutory consideration of objections, without any determination of the underlying tax liability.

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Issues: Whether the writ petitions, arising from show-cause notices and the rejection of revision petitions, should be disposed of by directing the petitioner to file objections before the assessing authority and by keeping recovery proceedings in abeyance.

Analysis: The notices were treated as show-cause notices, and it was recorded that the petitioner could raise objections, including the grounds urged in the revision petitions, before the first respondent. The first respondent was directed to consider those objections and pass orders on merits and in accordance with law. It was also made clear that no recovery proceedings should be initiated on the basis of the notices until such orders were passed.

Conclusion: The writ petitions were disposed of by directing the petitioner to submit objections before the assessing authority, with interim protection against recovery until fresh orders were passed.

Final Conclusion: The matter was not decided on the substantive tax liability, but was sent back to the statutory authority for consideration of objections with protection against coercive recovery in the meantime.

Ratio Decidendi: Where impugned communications operate as show-cause notices, the aggrieved party should first be allowed to place objections before the competent authority, and coercive recovery should await a fresh decision on merits.

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