Pending exemption claim requires time-bound decision after hearing, while substantive tax issues remain open for the proper forum.

A pending tax exemption certificate claim was not examined on its substantive merits because connected appellate proceedings and a remanded matter were already pending. The High Court confined relief to a limited mandamus directing the competent authority to consider and decide the exemption request expeditiously, after affording the taxpayer a reasonable opportunity of hearing and in accordance with law. The request was ordered to be decided within four months, while the assessment and demand issues were left open for determination before the appropriate forum.

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Issues: Whether the pending request for grant of exemption certificate in respect of the remaining quantity of production should be directed to be considered and decided expeditiously.

Analysis: The petition was confined to the limited grievance that the request for exemption certificate had remained pending for an inordinate period. In view of the pendency of the connected appellate proceedings and the remanded matter, the Court declined to enter into the merits of the assessment or the demand. Instead, it considered it appropriate to confine relief to a direction for disposal of the pending returns relating to the exemption certificate, after affording the petitioner a reasonable opportunity of hearing and in accordance with law, within a fixed time.

Conclusion: The request for exemption certificate was directed to be considered and decided within four months after hearing the petitioner.

Final Conclusion: The writ petition was disposed of with a limited mandamus for expeditious consideration of the exemption claim, leaving the substantive merits open before the appropriate forum.

Ratio Decidendi: Where a tax-related exemption claim remains pending, the writ court may grant a limited direction for time-bound decision after hearing the affected party without adjudicating the merits of the assessment or demand.

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