Judgment :- RAJU, J. The above writ appeals have been filed by the Revenue against the common order of a learned single Judge of this Court dated December 13, 1990 in W.P. Nos. 12100, 12101, 12102 and 12103 of 1989, which are being challenged in Writ Appeal Nos. 1172 to 1175 of 1992 respectively. The four writ petitions related to two assessment years, of which two each pertaining to the levy under the Tamil Nadu General Sales Tax Act, 1959 and the other two under the Central Sales Tax Act, 1956. The writ petitions were directed against the orders passed invoking the power under section55 of the Tamil Nadu General Sales Tax Act. Though the challenge was on several grounds, the learned single Judge was of the view that the respondent/assessee have been denied an effective opportunity and therefore, was pleased to allow an opportunity to the assessee to produce the accounts to substantiate their stand. It is against the order, directing the authorities to give a fresh opportunity to the assessee-company for production of the accounts and other records and to redo the assessment for the years 1983-84 and 1984-85, both under the Tamil Nadu General Sales Tax Act and the Central Sales Tax Act, that the appeals came to be filed. 2. Heard the learned Government Advocate (Taxes) Mr. T. Mathi, for the appellants and Mr. C. Natarajan, learned Senior Counsel, for the respondent/assessee. The learned Government Advocate (Taxes) with great care and strenuous efforts, contended that the order of the learned single Judge proceeding on the footing that there was a denial of opportunity or that the assessee should be given a further opportunity, is not well merited on the peculiar facts and circumstances of the case and that there had been considerable delay already and in spite of the assessing authorities' notices on four occasions, the assessee has not availed of the opportunities given and therefore, this Court ought not to have shown any further indulgence to the Assessee in this regard. 3. 3. Per contra, the learned Senior Counsel for the assessee, while emphasising upon the stakes involved and the normal practice in such matters, usually used to be adopted, contended that the assessee was made to believe, he can have further time and that there was no need for the assessee to withhold documents or records, inviting an adverse order against them, unless it was for the genuine feeling that the assessee was being lull on account of the normal procedure that was used to be adopted in such a case, and that the discretion exercised by the learned single Judge could not be said to have been so erroneously exercised as to warrant interference in our hands. 4. We have carefully considered the submissions of the learned counsel appearing on either side. We have been taken through the order of the learned Judge and other relevant materials to highlight the area of controversy between the parties and the magnitude of the problems involving the heavy tax commitments and the stand taken by the respective parties in their pleadings. The learned single Judge, as we could see, has come to notice one abnormal feature, which appears to have weighed with him very much to adopt the course which he has chosen to in this case when he observed : "Shorn of all technicalities, allegations and counter allegations, here is a case where for assessment years 1983-84 and 1984-85, something strange has happened and the assessment have no relation or comparison to the earlier or subsequent assessments......" * The learned Judge was also of the view that though the oral assurance of the taxing officers should never be accepted on the face value and that it is for the assessee to see that the provisions are complied with and accounts are produced at the proper time to avoid such embarrassing situation, the learned Judge thought fit on the facts and circumstances of the case that the petitioners must be given an opportunity to produce their accounts and satisfy the authorities about the correctness of their returns. We are also of the view that the assessees also cannot afford to antagonise that much the authorities and the explanation given by the assessee that they were led to believe and act on the oral assurance of the taxing officers though they ought not to have done so, could not be altogether rejected as borne out of imagination or as a pure afterthought. Hence, on an overall consideration of the matter also, we are of the view that the learned single Judge could not be said to have exercised his discretion in an unreasonable manner or in any manner opposed to law warranting our interference. The nature and extent of an opportunity to be accorded in a given case depends upon the magnitude of the problem as also the merits of the claim and the exigencies of a situation and if the learned single Judge has taken into account all these aspects to grant a relief in the nature of a further opportunity only to enable the assessee to produce their accounts and other records, with a direction to the authorities to redo the assessment, we see no error, at any rate patent error of law, warranting our interference. The appeals, therefore, fail and shall stand dismissed. No costs.