Provisional assessment finalisation upheld where the order disclosed its basis and technical objections did not defeat completion.

Provisional assessments may be finalised by the proper officer after reasonable enquiry when valuation remains pending, and technical objections do not invalidate the finalisation if the order substantially discloses its basis. The absence of a specific price-list number, alleged vagueness, and claims that the order was non-speaking were treated as technical defects because the order clearly showed that provisional assessments were being concluded. The pending collateral show-cause notice did not displace the finalisation. The challenge to the order approving the provisional price lists and directing final assessment therefore failed.

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Issues: Whether the Assistant Collector's order finally approving the provisional price lists and directing final assessment was liable to be set aside for want of a price-list number, alleged vagueness, alleged non-speaking nature, and the pendency of other proceedings.

Analysis: The order was made in the context of assessments kept provisional because the valuation dispute was pending before the Supreme Court. The Assistant Collector, as the proper officer, was competent to finalise the price lists and to cause enquiry through the Range Superintendent. The objections regarding absence of a specific price-list number and the alleged vagueness of the direction were treated as technical, since the order clearly indicated that the provisional assessments were being finalised. The order was also held to be sufficiently speaking, because it recorded the factual basis for treating the sales as on a principal-to-principal basis at arm's length and as normal price sales. The pending show-cause notice did not furnish a ground to disturb the appellate order.

Conclusion: The order approving the provisional price lists and finalising assessment was upheld, and the Revenue's challenge failed.

Ratio Decidendi: An assessment kept provisional pending judicial determination may be finalised by the proper officer on the basis of a reasonable enquiry, and technical objections such as omission of a price-list number, alleged vagueness, or a pending collateral notice do not by themselves vitiate the finalisation where the order substantially discloses its basis.

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