Writ challenge to tax assessment orders barred by laches when statutory appeals were hopelessly delayed and Covid-19 excuse failed.

A writ challenge to tax assessment and appellate orders was held not entertainable where the statutory appeals were filed beyond the prescribed limitation and even beyond the period the appellate authority could condone. The plea that Covid-19 caused the delay was rejected because the limitation period had already expired before the pandemic began. The petitioners then remained inactive for years and approached the Court only after demand notices were issued. On these facts, the writ petitions were barred by laches, were not examined on merits, and only the limited course of seeking particulars of the demand from the assessing authorities was left open.

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Issues: Whether the writ petitions challenging the assessment orders and the appellate orders were liable to be entertained despite inordinate delay and laches.

Analysis: The assessments were made in August 2019 and the statutory appeals were filed beyond the period of limitation and beyond the further period that could be condoned by the appellate authority. The plea that the delay was caused by the Covid-19 pandemic was rejected because the limitation period had already expired before the pandemic outbreak. The petitioners also remained inactive for several years after dismissal of the appeals and approached the Court only after demand notices were issued. On these facts, the challenge to the assessment and appellate orders could not be entertained.

Conclusion: The writ petitions were barred by laches and the challenge to the assessment orders and appellate orders failed.

Final Conclusion: The petitions were not adjudicated on merits and were disposed of, while leaving open only the limited course of seeking particulars of the demand from the assessing authorities.

Ratio Decidendi: A writ challenge to tax assessments and appellate orders will not be entertained where the statutory appeal was filed beyond condonable time and the party approaches the Court after an unexplained, prolonged delay.

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