Payment of admitted tax liabilities: time allowed to pay outstanding liabilities for specified assessment years; writ petition disposed.

The petition concerned deferment of tax recovery and a request for time to pay admitted tax liabilities for specific assessment years. The court, invoking the interest of justice, considered the petitioner's limited request for additional time and directed the petitioner to make payment of the admitted tax liabilities for the remaining assessment years. As a consequence of that direction, the writ petition was disposed of, with the operative effect that recovery proceedings were addressed by ordering payment rather than further stay or remittal on the facts presented.

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Issues: Whether the petitioner should be granted time to pay admitted tax liabilities for assessment years 2017-2018, 2018-2019 and 2020-2021 and whether recovery proceedings in respect of those years should be deferred.

Analysis: The petition concerns recovery proceedings for multiple assessment years, of which separate orders already operate in respect of AY 2019-2020 (stay) and AY 2023-2024 (set aside and remitted). The remaining years involve admitted liabilities which the petitioner proposes to pay within a specified short period. The relief sought in relation to these remaining years is limited to a time extension for payment and suspension of recovery pending such payment. The Court considered the limited nature of the relief sought, the existence of stayed/remitted proceedings for other years, and the interest of justice in permitting an orderly discharge of admitted liabilities while preventing immediate coercive recovery.

Conclusion: The petitioner is granted four weeks' time to pay the admitted tax liabilities for AY 2017-2018, 2018-2019 and 2020-2021 and recovery proceedings in respect of those years are directed to be deferred until the said date; this disposition is in favour of the assessee.

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