Higher authority declines to decide reassessment challenge, directs petitioner to pursue statutory appeal and interim relief options

The HC declined to adjudicate the challenge to the reassessment and instead relegated the petitioner to the statutory appellate remedy, permitting institution of an appeal against the assessment order. The HC refused to decide on interim relief at this stage but granted the petitioner liberty to apply to the appellate authority for interim relief and to rely on precedents they contend support their case. All parties' contentions were left open for resolution by the Appellate Authority.

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Heard counsel. Pending final disposal, an Assessment Order dated 27 March 2025 was passed after interim relief was refused. While the Court could address jurisdictional issues, it would be difficult to decide merits of the Assessment Order; the Appellate Court is "in a position to comprehensively decide on the issues of jurisdiction and merits." The Petition is disposed by relegating the Petitioner to "avail of the alternate statutory remedy of Appeal against the Assessment Order dated 27 March 2025." All contentions raised in the Petition are "explicitly left open to be raised in such Appeal." The Petitioner may apply for interim relief before the appellate authority and "rely upon the decisions" they seek; the Court declines to rule on interim relief while the appeal remedy is available. The appellate/interim authority is expected to consider all contentions and decisions relied upon. No costs; rule disposed.

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