Writ petition against revision notice is premature when objections and a hearing remain available before the assessing authority.

Writ jurisdiction is ordinarily premature against a revision notice where the assessee has been called upon to file objections and the statutory decision-making process is still pending. The court treated the notice as an intermediate step, noted that an effective remedy remained before the assessing authority, and held that the assessee should first pursue that objection process. The authority was required to consider the objections after granting a hearing, with status quo maintained in the meantime. The writ petition was therefore not entertained on merits, and the assessee was relegated to the statutory process.

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Issues: Whether a writ petition challenging a revision notice was maintainable when the assessee had been called upon to file objections and the statutory decision-making process was still pending.

Analysis: The assessment had already been revised only at the notice stage, and the assessee had been given an opportunity to submit objections. In such a situation, invocation of writ jurisdiction was held to be premature, as the assessee had not yet exhausted the immediate remedy available before the assessing authority. The Court therefore directed the assessee to submit objections and required the authority to consider them after granting a hearing, while maintaining status quo in the meantime.

Conclusion: The writ petition was not entertained on merits and the assessee was relegated to the statutory objection process.

Ratio Decidendi: Writ jurisdiction should ordinarily not be invoked against a revision notice when the assessee has an effective opportunity to file objections and secure a hearing before the assessing authority.

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