Criminal court cannot re-examine a final tax assessment when enforcing prosecution for non-payment of assessed tax.

Where a taxing statute provides a complete machinery for assessment, objection, appeal, revision, and reference, the assessee must challenge the assessment through those statutory remedies. If that mechanism is not invoked in time, the assessment becomes final and the liability to pay arises. In prosecutions for non-payment of assessed tax, the criminal court's role is confined to checking whether the assessee became liable under the Act and failed to pay the assessed amount. It cannot reopen the legality or ultra vires character of the assessment, especially where the penal provision refers to failure to pay "tax assessed" rather than "tax due."

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Issues: Whether a criminal court can examine the validity of a tax assessment and refuse to enforce payment on the ground that the assessment is illegal or ultra vires.

Analysis: The Mysore Sales Tax Act provided a complete machinery for assessment, objection, appeal, revision, and reference on questions of law. The assessee could contest the correctness and legality of the assessment before the assessing authority and, if necessary, through the statutory appellate and revisional remedies. Once that machinery was not invoked within time, the assessment became final and the statutory obligation to pay arose. In prosecutions under Section 20(b), the criminal court's role was limited to seeing whether the assessee had become liable under the Act and had failed to pay the assessed tax. The wording of the penal provision, referring to failure to pay "tax assessed", differed from provisions using the expression "tax due", and did not permit a fresh inquiry into the legality of the assessment.

Conclusion: The criminal court had no jurisdiction to reopen the validity of the assessment in these prosecutions, and the convictions were upheld.

Final Conclusion: The petitions failed, the convictions stood, and only the sentence in one case was reduced.

Ratio Decidendi: Where a taxing statute provides a complete statutory mechanism for challenging an assessment, a criminal court enforcing non-payment of the assessed tax cannot re-examine the validity of that assessment.

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