in the present case as narrated herein before, are somewhat peculiar. The petitioner has questioned provisional assessment orders within a few days of passing of the same, by filing two writ petitions. Both parties evidently presumed that the interim stay granted on 07.01.2003 continued. However, respondent No.3 obviously realised that the interim stay was granted only for a limited period and raised a demand on 04.10.2010, for payment of balance tax due under the final assessment orders dated 17.08.2004. The petitioner questioned the final assessment orders by filing amendment petitions, within less than two months of passing of the final assessment orders. This Court has granted interim stay of collection of the disputed tax under the final assessment orders by order dated 05.01.2011, which was continued till the writ petitions were dismissed on 27.07.2017. From these facts, it cannot be said that the petitioner was not diligent in pursuing his cause. However, he has availed inappropriate legal remedies by filing writ petitions and applications for amendment of the prayer in the said writ petitions, questioning the final assessment orders. Under these facts of the case, no negligence or laches could be attributed to the petitioner. The petitioner, instead of pursuing these writ petitions, wants to avail the remedy of appeals. In our opinion, if the writ petitions do not suffer from laches, the same reasoning would hold good for permitting the petitioner to file appeals, though the limitation for filing appeals has expired long time back. As the lis was kept alive all through, and in the facts and
