In view of the above, this Court would be slow in entertaining writ petitions for the prayers as noted above and would, thus, relegate the petitioner to the concerned Commercial Court for mediation, settlement, and adjudication as above.

Therefore, the petitioner has made out a prima facie case on this short score. Accordingly, the impugned order dated 21.09.2017 stands set aside reserving liberty to the concerned authority to pass a fresh order after due taking note of the Apex Court's decision (cited supra) and proceed to pass a fresh order. In the meanwhile, the petitioner is permitted to file an additional reply to the show cause notice and proposed show cause notice insofar as blacklisting and consequential order. Above exercise shall be completed within a period of three months from the date of receipt of this order, by the competent authority.

Patna High Court CWJC No.4564 of 2023 dt.18-04-2023 3/4 Learned counsel for the petitioner submits that in accordance with the notification, a return has been filed and the liability to interest and late fee is also satisfied. Definitely, the Assessing Officer would be entitled to verify whether there is due compliance under the notification, herein above extracted, and if the compliance is in accordance with the notification, the assessment order would stand withdrawn.

In the light of instructions to the bidders, in particular, Clause 4.8 of Section(1)-Instruction to Bidders (ITB) is crystal clear. Therefore, there is no infirmity in the impugned action.

The appeal is said to have been filed only on 02.12.2022, after about six months from the date on which even the limitation period, as stipulated by the Hon'ble Supreme Court, expired. In the above circumstances, we find no reason to invoke the extraordinary jurisdiction under Article 226, especially since it is not a measure to be employed where there are alternate remedies available and the assessee has not been diligent in availing such alternate remedies within the stipulated Patna High Court CWJC No.4466 of 2023 dt.17-04-2023 3/3 time.