Pending rectification application must be heard and decided promptly, with an opportunity of hearing before disposal.

A pending rectification application that had been received but remained undisposed of entitled the appellant to a direction for expeditious disposal rather than any final determination of the assessment merits. The grievance was limited to non-disposal of the rectification request, so the court directed that the application be heard and decided promptly after giving the appellant an opportunity of hearing. Liberty was also granted to re-submit the application. The ruling is confined to securing consideration of the pending rectification application and does not decide the substantive tax dispute.

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Issues: Whether the appellant was entitled to a direction for disposal of the pending rectification application.

Analysis: The rectification application had been received and was stated to remain undisposed of. In that situation, the appellant's grievance was confined to non-disposal of the application rather than a final adjudication on the merits of the assessment. A direction for expeditious disposal, after hearing the appellant, was therefore warranted.

Conclusion: The appellant was entitled to a direction requiring disposal of the rectification application, with an opportunity of hearing, and liberty to re-submit the application was also granted.

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