Statutory appeal rights: petitioner granted six weeks to file; appellate authority must hear and decide on merits.

Petitioner may prefer a statutory appeal against the final assessment; the SC granted additional time and permitted filing within six weeks, directing that any such appeal be entertained notwithstanding limitation and decided on merits. The appellate authority must consider all grounds and documentary evidence (including specific documentary requests), afford an opportunity of personal hearing, and pass a reasoned order expeditiously. Earlier observations in writ proceedings must not preclude fresh consideration on merits. The Special Leave Petition is disposed; relief is limited to permit and mandate proper adjudication of the statutory appeal within the specified timeframe.

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Issues: Whether the petitioner should be permitted to prefer an appropriate statutory appeal before the appellate authority against the final order of assessment and, if so, the period within which the appeal may be filed and the manner in which the appellate authority should decide the appeal.

Analysis: The High Court directed that a statutory appeal may be filed and considered without reference to limitation if filed within a specified period and that the appellate authority should consider all grounds and documents and afford an opportunity of personal hearing before passing a reasoned order on merits. The present order grants the petitioner additional time to file an appeal against the final order of assessment and clarifies that any appeal so filed shall be entertained and decided on merits. The appellate authority is directed to take up and decide the appeal expeditiously, to consider all contentions and relevant documents (including specific documentary requests such as Fastag details), and not to be influenced by earlier observations made in the writ proceedings.

Conclusion: The petitioner is permitted to prefer an appropriate statutory appeal within six weeks from the date of this order; any such appeal shall be heard expeditiously by the appellate authority and decided on its own merits after affording opportunity of personal hearing and considering all grounds and documents. The Special Leave Petition stands disposed of.

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