Provisional assessment direction pending SSI certificate is not a final appealable order and cannot support appellate interference.

A provisional assessment direction pending production of a permanent SSI registration certificate does not amount to a final adjudication of exemption entitlement. Because the communication remained conditional and capable of modification on fulfilment of the stated requirement, it was not an appealable final order. The Commissioner (Appeals) therefore lacked a valid basis to interfere with that communication, and the appellate order was legally infirm.

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Issues: Whether the Assistant Collector's communication directing provisional assessment was a final and appealable order, and whether the order of the Commissioner (Appeals) granting relief could be sustained.

Analysis: The communication issued by the Assistant Collector was only a direction for provisional assessment pending production of the permanent SSI registration certificate. It did not finally determine the assessee's entitlement to the exemption claim and remained subject to the subsequent final order. An order that is provisional in nature and capable of modification on fulfilment of the stated condition does not attain the character of a final adjudication for appellate purposes.

Conclusion: The Assistant Collector's communication was not an appealable final order, the Commissioner (Appeals) had no valid basis to interfere, and the appellate order suffered from legal infirmity.

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