Writ relief against assessment notices refused where no prior objection was filed before the assessing authority

Assessment notices were challenged in writ jurisdiction on the ground of limitation and lack of jurisdiction, but no objection or reply had first been filed before the assessing authority. In these circumstances, the High Court declined to interfere at the notice stage and directed the petitioner to submit a detailed objection/reply before the competent authority. The authority was required to consider the objection after hearing the petitioner and pass a speaking order. The effect is that writ relief against the notices was refused and the dispute was left to be decided through the statutory objection process.

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Issues: Whether the notices issued for assessment could be quashed in writ jurisdiction on the ground of limitation without first filing objections before the assessing authority.

Analysis: The writ petition challenged the assessment notices on the plea that the proceedings were time-barred and without jurisdiction. The Court noted that no objection or reply had been filed before the competent authority and that the petitioner had approached the writ court against the notices. In these circumstances, the Court found no justifiable reason to interfere at the notice stage and instead directed the petitioner to place a detailed objection/reply before the authority, which was to decide it after hearing the petitioner by a speaking order.

Conclusion: The writ relief against the notices was declined, and the petitioner was left to pursue objections before the assessing authority.

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