Statutory remedies bar writ interference, and tax-free purchase exemption does not extend to processing third-party cloth for labour charges.

Writ jurisdiction was treated as inappropriate where the sales tax statute provided appeal, revision and reference remedies, and alleged fundamental rights infringement did not by itself justify bypassing those remedies. Tax-free purchases covered by a registration certificate were held not to extend to bleaching, dyeing and finishing of cloth belonging to third parties, because the exemption applied to goods used by the dealer in manufacturing goods for sale and the record did not show coverage for such processing on labour charges. The challenge therefore failed on maintainability and on merits, and the assessment was sustained.

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Issues: (i) Whether the writ petition under Articles 226 and 227 of the Constitution should be entertained despite the availability of statutory appeal and other remedies under the sales tax law; (ii) Whether goods purchased free of tax under the registration certificate could be treated as used in the manufacture of any goods for sale when they were consumed in bleaching, dyeing and finishing cloth belonging to third parties.

Issue (i): Whether the writ petition under Articles 226 and 227 of the Constitution should be entertained despite the availability of statutory appeal and other remedies under the sales tax law.

Analysis: The availability of appeal, revision and reference under the sales tax statute was a material factor against interference in writ jurisdiction. The petitioner's reliance on alleged infringement of fundamental rights did not by itself compel the High Court to bypass the ordinary statutory remedies. Since the petitioner had already invoked the appellate process and the case did not disclose such exceptional circumstances as to justify immediate exercise of extraordinary jurisdiction, the Court declined to interfere on this ground.

Conclusion: The writ petition was not maintainable as a matter for discretionary interference and the petitioner was required to pursue the statutory remedies.

Issue (ii): Whether goods purchased free of tax under the registration certificate could be treated as used in the manufacture of any goods for sale when they were consumed in bleaching, dyeing and finishing cloth belonging to third parties.

Analysis: The exemption under section 5(2)(a)(ii) applied only to goods specified in the registration certificate for use by the dealer in the manufacture of goods for sale or in the execution of a contract. On the facts, the goods were used in processing cloth that remained the property of third parties, and the dealer was earning labour charges rather than manufacturing goods for his own sale. The registration certificate did not grant an exemption for use in execution of contracts, and the record did not support the claim that the tax-free purchases were covered by the manufacturing exemption.

Conclusion: The petitioner was not entitled to tax exemption on the goods used in processing third-party cloth, and the assessment was upheld.

Final Conclusion: The challenge to the sales tax assessment failed both on maintainability and on merits, and the assessment order was sustained.

Ratio Decidendi: A writ court will ordinarily decline to interfere where an adequate statutory remedy exists, and tax-free purchase exemptions for goods specified for manufacture extend only to use in the manufacture of goods for sale by the dealer, not to processing of third-party goods for labour charges.

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