Conditional interim relief permits completion of assessment before limitation expires, while keeping merits and enforcement issues open.

Conditional interim relief was granted to permit completion of the 2019-20 assessment before it became time barred, while preserving the assessee's challenge on the merits. The State Tax Department was allowed to finalise the assessment, but any adverse assessment was protected from enforcement and remained subject to further orders in the writ petition. Both parties' contentions on the assessment were expressly kept open, so the permission operated only as a safeguard against limitation and did not decide the substantive dispute.

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Issues: Whether the State Tax Department should be permitted, by modification of the earlier order, to complete the assessment for assessment year 2019-20 in respect of the assessee.

Analysis: The requested relief was limited to enabling completion of the assessment before it became time barred. The permission was granted on a protective footing, with the safeguard that any adverse assessment would not be enforced and would remain subject to further orders in the writ petition. The contentions of both sides on the assessment were expressly kept open.

Conclusion: The interim application was allowed and the State was permitted to complete the assessment for 2019-20, subject to the stated protection.

Final Conclusion: The Court granted conditional permission to complete the assessment while preserving the assessee's challenge against any adverse consequence and leaving the merits undecided.

Ratio Decidendi: Where assessment would otherwise become time barred, the Court may permit its completion by way of conditional interim relief while keeping the merits open and protecting the assessee against enforcement of any adverse assessment pending further orders.

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