Statutory application must be decided promptly, and linked assessment may be stayed pending disposal to avoid prejudice.

Where the U. P. Sales Tax Rules empowered the Commissioner to issue directions on application, the authority was required to apply its mind and decide the application one way or the other within a reasonable time. Because the assessment for the relevant year was still pending and could create adverse liability, the Court directed that the application be decided within four weeks and protected the petitioner by keeping the assessment unfinalised, or ineffective if already made, until that decision was taken.

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Issues: Whether the Commissioner was required to decide the petitioner's application under the U. P. Sales Tax Rules for issuance of directions, and whether the assessment proceedings could be finalised before such decision.

Analysis: The Rules empowered the Commissioner to issue directions on an application by a party. Once such an application had been made, the authority was obliged to apply his mind and take a decision one way or the other. Since the assessment for the relevant year was pending and could result in a liability against the petitioner, the Court also considered it appropriate to protect the petitioner from adverse finalisation until the application was disposed of.

Conclusion: The Commissioner was directed to decide the application within four weeks, and the assessment for the relevant year was to remain unfinalised, or if already made, not to be given effect to, until disposal of that application.

Final Conclusion: The petitioner obtained limited substantive relief by securing a time-bound decision on its application and interim protection against final assessment action pending that decision.

Ratio Decidendi: Where a statutory authority is empowered to issue directions on application, the authority must decide the application within a reasonable time, and pending such decision the connected assessment action may be restrained to prevent prejudice.

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