Pending request to revise return must be decided before assessment proceedings continue under Section 25(1).

Where a request for permission to revise a return was pending and no decision had been communicated, continuation of assessment proceedings based on the notice under Section 25(1) was considered inappropriate until that request was decided. The assessing authority was directed to dispose of the revision request expeditiously, communicate the decision to the taxpayer, and keep further proceedings in abeyance meanwhile.

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Issues: Whether the petitioner was entitled to a direction to the assessing authority to decide the pending request for permission to revise the return and to keep further proceedings in abeyance until such decision was taken.

Analysis: The request for permission to revise the return had been made and no order on that request had been communicated. In that situation, continuation of assessment proceedings based on the notice issued under Section 25(1) would not be appropriate until the pending request was decided and communicated. The appropriate course was to require the authority to act on the request expeditiously and, meanwhile, defer further proceedings.

Conclusion: The petition was disposed of by directing the first respondent to pass orders on the revision request and communicate the decision to the petitioner within two weeks, and to keep further proceedings pursuant to the notice in abeyance until then.

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