Annual assessment option supports interim stay where vessel-wise demands conflict with consolidated return-processing refund intimation.

Interim protection against vessel-wise assessments was considered where an assessee had opted for annual assessment and its consolidated return-processing intimation showed a final refund. The coexistence of assessment demands under the shipping-income provision and a refund intimation created an arguable controversy requiring deeper consideration. On this prima facie basis, operation and enforcement of the impugned assessment orders, demand notices, and consequential recovery proceedings were stayed pending final disposal of the writ petition.

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Issues: Whether interim protection should be granted against vessel-wise assessments and consequential demand where the assessee had exercised the option for annual assessment and its consolidated return resulted in a final refund.

Analysis: The coexistence of assessment demands under the shipping-income provision and a final return-processing intimation granting refund disclosed an arguable controversy requiring deeper consideration. The competing assessments and refund established a prima facie case for protection pending adjudication.

Outcome: Rule issued; operation and enforcement of the impugned assessment orders, demand notices, and consequential recovery proceedings stayed pending final disposal of the writ petition.

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