Civil court jurisdiction barred for suits seeking to invalidate sales tax assessments under the statutory challenge mechanism.

Civil court jurisdiction is barred where a suit in substance seeks to set aside or modify a sales tax assessment under the Madras General Sales Tax Act. Section 9 CPC yields to the Act's express exclusion in section 18-A, and the assessment must be challenged through the statute's complete appellate and revisional machinery under sections 11 and 12 to 12-D. Describing the assessment as illegal, ultra vires, or unsustainable on merits does not make the suit maintainable when the relief sought is effectively to invalidate the assessment.

---

---

Issues: Whether the civil court had jurisdiction to entertain a suit seeking to set aside or modify a sales tax assessment made under the Madras General Sales Tax Act.

Analysis: Section 9 of the Code of Civil Procedure confers jurisdiction on civil courts in matters of civil nature except where such jurisdiction is expressly or impliedly barred. Section 18-A of the Madras General Sales Tax Act expressly withdraws from civil court scrutiny suits aimed at setting aside or modifying assessments made under the Act. The Act provides a complete and self-contained machinery under sections 11 and 12 to 12-D for an assessee to challenge the assessment, and a prayer which in substance seeks to invalidate the assessment must be pursued only through that statutory hierarchy. A challenge describing the assessment as illegal, ultra vires, or unsustainable on the merits does not convert the matter into one maintainable before the civil court when the substance of the relief is to set aside the assessment.

Conclusion: The civil court's jurisdiction was barred and the suit was not maintainable.

---