State bifurcation and pending writ petition required preservation of appellate remedy, with assessments to be completed by the proper authority.

Assessment orders issued by the authorities of the undivided State were challenged after State bifurcation, while demand was later being pursued by the successor State. To preserve the taxpayer's effective appellate remedy and avoid a situation where no authority could properly complete the assessments after the pending writ petition, the Supreme Court set aside the High Court judgment and the assessment orders. It also directed that the matter be considered in light of Clause III(i) of Schedule V of the Andhra Pradesh Infrastructure Development Enabling Act, 2001 and the Andhra Pradesh Re-Organisation Act, 2014, with liberty to the concerned assessing authority to complete the assessments after disposal of the writ petition.

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Issues: Whether the impugned High Court judgment and the assessment orders could be set aside in view of the bifurcation of the State and the pending writ petition, with liberty to the concerned assessing authority to complete the assessments after disposal of the writ petition.

Analysis: The assessment orders had been passed by the authorities of the undivided State, while demand was subsequently being raised by authorities of the successor State after bifurcation. The Court accepted the contention that, if the petitioner failed in the pending writ petition, it should not be left without an effective remedy against the assessment orders before either State. To preserve the petitioner's appellate remedy and to ensure that the assessments could be completed by the appropriate authority after the writ petition was decided, the Court set aside the earlier orders and required the High Court to keep in view Clause III(i) of Schedule V of the Andhra Pradesh Infrastructure Development Enabling Act, 2001 and the Andhra Pradesh Re-Organisation Act, 2014.

Conclusion: The impugned High Court judgment and the assessment orders were set aside, and liberty was reserved to the concerned State assessing authority to complete the assessments after disposal of the pending writ petition.

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