Pandemic-related delay and directory limitation under tax procedure leave the writ petitioner to pursue the statutory appeal.

Section 73(4B)(d) was treated as directory in the circumstances, and delay caused during the pandemic was accepted as sufficiently explained. The writ challenge was not examined on merits because the petitioner was relegated to the statutory appellate remedy, with liberty to seek exclusion of the time spent in writ proceedings. The document also notes that repeated notices for personal hearing had been issued, and the petitioner relied on the same pandemic period for non-appearance.

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Issues: Whether the writ petition could be entertained despite the delay beyond the period contemplated under Section 73(4B)(d) on the ground of the pandemic and whether the petitioner should be relegated to an appellate remedy.

Analysis: The limitation prescribed in Section 73(4B)(d) was treated as directory and not mandatory in the circumstances considered. The delay in completing the proceedings was accepted as sufficiently explained by the pandemic period, especially when notices for personal hearing had been issued over time and the petitioner also relied on the same period for non-appearance. In these circumstances, the Court declined to exercise writ jurisdiction on merits and preserved the petitioner's right to pursue the statutory appeal with exclusion of the time spent in writ proceedings.

Conclusion: The challenge was not entertained on merits and the writ petition was rejected, leaving the petitioner to avail the appellate remedy.

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