Pending revision against assessment can justify stay of recovery and prompt disposal by the revisional authority.

Pending revision petitions challenging an assessment justified interim protection against coercive recovery, because the revisional authority had to consider whether the assessment under section 18(4) was completed before service of the pre-assessment notice. The Kerala HC declined to examine the merits of the writ contentions while the revisions remained pending, and instead restrained further recovery under the assessment order and revenue recovery notice. It also directed the revisional authority to dispose of the revision petitions within three months, leaving the substantive legality of the assessment to be decided in revision.

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Issues: Whether recovery proceedings under the assessment and revenue recovery notice should be stayed pending disposal of the revision petitions and whether the revisional authority should be directed to dispose of the revisions expeditiously.

Analysis: The assessment had been challenged in revision and those revision petitions were shown to be pending. The Court found that the petitioner's challenge, including the contention that the assessment under section 18(4) may have been completed before service of the pre-assessment notice, required consideration by the revisional authority. In view of the pending revisions, the Court declined to examine the merits of the other contentions in the writ proceedings and instead granted interim protection against coercive recovery.

Conclusion: The revisional authority was directed to dispose of the revision petitions within three months, and all further recovery proceedings under the assessment order and revenue recovery notice were stayed pending such disposal.

Final Conclusion: The petitioner obtained interim protection and a time-bound direction for disposal of the pending revisions, while the substantive legality of the assessment was left to be decided in revision.

Ratio Decidendi: Where revision against an assessment is pending, the Court may grant stay of recovery and require expeditious disposal by the revisional authority without entering upon the merits of the assessment itself.

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