Alternative statutory remedy bars writ challenge to sales tax liability where the tax act provides complete appellate machinery.

A writ petition under Article 226 was held ordinarily unavailable to challenge sales tax liability where the East Punjab General Sales Tax Act, 1948 provided a complete statutory machinery for determination, assessment, payment, appeal, revision, and reference. The availability of an adequate and efficacious alternative remedy was treated as sufficient reason to decline writ interference, since the petition sought to bypass the special procedure created by the taxing statute. The decision underscores that High Court writ jurisdiction will not normally be used to short-circuit an effective internal remedy structure in tax matters.

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Issues: Whether a writ petition under Article 226 could be entertained to challenge sales tax liability when the East Punjab General Sales Tax Act, 1948 provided a complete machinery of objection, appeal, revision, and reference.

Analysis: The petitions sought to bypass the statutory procedure prescribed by the sales tax enactment. The Act contained provisions for determination of liability, assessment, payment, appeal, revision, and reference to the High Court. In view of that complete remedial scheme, the availability of writ relief was held not to justify short-circuiting the special procedure. The existence of a suitable and efficacious alternative remedy was treated as a sufficient ground for refusing interference under Article 226.

Conclusion: The writ petitions were not maintainable for bypassing the statutory remedy, and the challenge to the tax demand was rejected.

Final Conclusion: The decision affirms that where a taxing statute provides an effective internal remedy structure, the High Court will ordinarily decline to exercise writ jurisdiction to interrupt that process.

Ratio Decidendi: Writ jurisdiction will not ordinarily be invoked to challenge a tax assessment or liability when the statute itself provides an adequate and efficacious machinery for determination, appeal, revision, and reference.

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