Permission granted to petitioner to move High Court for review regarding withdrawal of writ petitions. High Court had allowed withdrawal but petitioner claims it was subject to certain conditions. The submission cannot be made before this Court but may be made before High Court. No opinion expressed on the merits of the submission. Special Leave Petitions are disposed of, but the order does not affect the assessment proceedings.

1. Mr Mukul Rohatgi, learned Senior Counsel appearing on behalf of the petitioner relied upon the contents of the affidavit which was filed by the petitioner on 27 January 2020 before the High Court (Annexure P-10 to the paper book). Adverting to paragraph 16 of the affidavit, it has been submitted that the petitioner had applied for withdrawal of the writ petitions in view of the submission which was made in paragraph 13. Hence, it has been urged that the prayer for withdrawal was not unconditional, but was subject to what was averred in paragraph 13 of the affidavit. The High Court allowed the writ petitions to be withdrawn simpliciter.

2. Since the High Court, in paragraph 1 of the judgment, recorded that the learned counsel for the petitioner made an endorsement withdrawing the writ petitions seeking liberty to put forth all his contentions on merits or otherwise before the Assessing Authority in the course of assessment proceedings, we are of the view that any such submission as recorded above can only be made before the High Court by way of review. In view of what is stated in paragraph 1 of the impugned judgment, it would be inappropriate for this Court to decide on the merits of the aforesaid grievance.

3. We accordingly permit the petitioner to move the High Court by way of a review.No opinion is expressed on the merits of the above submission by this Court. The present order shall not affect the assessment proceedings.

4. Subject to the aforesaid, the Special Leave Petitions are disposed of.

(SANJAY KUMAR-I) (SAROJ KUMARI GAUR)