Tax exemption sought in writ proceedings was left to government consideration, with no merits ruling on the assessments.

Petitioners sought quashing of assessment and demand orders and a mandamus for exemption notifications under the tax regime, but no merits determination was made on tax liability or exemption entitlement. The Court treated exemption as a policy matter for the Government to consider and indicated that the petitioners could pursue the remedy available in law for arrears. The writ proceedings were therefore disposed of with a direction for governmental consideration, without any substantive ruling on the validity of the impugned assessments.

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Issues: Whether the petitioners were entitled to immediate judicial quashing of the assessment and demand orders or to a mandamus directing issuance of exemption notifications under the tax regime.

Analysis: The relief sought centred on exemption from tax and challenge to the assessments, but the matter was not finally adjudicated on merits. The Court left the question of exemption to be considered by the Government as a policy matter and indicated that the petitioners could pursue the remedy available in law for arrears. The order was thus one of administrative consideration rather than substantive adjudication of liability.

Conclusion: No final adjudication on the validity of the assessments or entitlement to exemption was recorded in the writ proceedings; the Government was directed to consider the petitioners' case and the petitions were disposed of.

Final Conclusion: The proceedings ended with a direction for governmental consideration of the exemption issue, without a merits determination on the impugned assessments.

Ratio Decidendi: Where the Court directs the competent Government to consider exemption as a policy matter, without deciding the legality of the assessments, the proceeding is disposed of without a substantive ruling on tax liability.

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