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Issues: Whether a writ of prohibition should be issued when the Madras General Sales Tax Act provides a complete hierarchy of assessment, appeal, revision, and High Court review remedies.
Analysis: The Act was treated as a self-contained scheme creating successive statutory remedies before the assessing authority, appellate authority, revisional authorities, the Appellate Tribunal, and the High Court. The availability of these remedies meant that the dispute over the rate of tax and the construction of the Act and Rules was one for the tribunals created by the statute. The fact that the assessee had to pay tax before appeal, or that the statutory process might involve delay, expense, or difficulty, was held to be no ground for bypassing the remedies provided by the Act. The existence of an appeal already pending and the possibility of further revision also showed that the statutory machinery had not been exhausted.
Conclusion: The writ of prohibition was not maintainable in view of the adequate and effective alternative remedy under the Act.
Ratio Decidendi: Where a special fiscal statute provides a complete and effective hierarchy of remedies for assessment disputes, the extraordinary writ jurisdiction will not be invoked merely because the statutory remedy is burdensome, delayed, or requires payment of tax as a condition for appeal.