Limitation-based writ restoration permits unresolved reassessment challenges, while coercive recovery and penalty action remain restrained pending proceedings.

Restoration of a writ petition was considered appropriate because its earlier disposal addressed only limitation, and a subsequent Supreme Court ruling required limitation to be computed under applicable relaxation legislation. Unresolved challenges, including whether the reassessment notice fell within the surviving period, were left for consideration without requiring a fresh petition. Maintainability in light of the alternate statutory remedy remained open. The petition was restored and listed for admission, while coercive recovery under the assessment order and demand notice, and action under penalty notices, were restrained pending further orders.

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Issues: Whether the writ petition, previously disposed of solely on limitation, should be restored after the earlier order was set aside, and whether coercive recovery and penalty action should be restrained pending further proceedings.

Analysis: The earlier disposal addressed only limitation. The Supreme Court's subsequent ruling required limitation to be computed under the applicable relaxation legislation, while the remaining challenges, including whether the reassessment notice fell within the surviving period, had not been adjudicated. Restoration was therefore appropriate to permit consideration of those unresolved issues without requiring a fresh petition. The question of maintainability in view of the alternate statutory remedy was expressly kept open.

Outcome: The writ petition was restored and listed for admission; coercive action pursuant to the assessment order, demand notice and penalty notices was restrained until further orders.

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