Personal bias in assessment proceedings can vitiate orders and justify writ interference despite an available appellate remedy.

A quasi-judicial assessment is invalid where objective circumstances create a reasonable apprehension of personal bias, and the defect vitiates the assessment orders. The recorded facts-altercation during survey, prosecution initiated by the assessing officer, unexplained alteration of dates, refusal to transfer the case, rejection of adjournment, and best judgment assessments on substantially the same material-were treated as establishing bias. The availability of an appellate remedy did not bar writ interference where the order was affected by denial of justice and illegality going to jurisdiction. The assessment orders were quashed, and the consequential demand notices also fell.

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Issues: Whether the assessment orders were vitiated by personal bias on the part of the assessing officer, and whether the existence of an alternative remedy barred interference under Article 226.

Analysis: Bias is fatal where the circumstances give rise to a reasonable apprehension that the authority could not act impartially. On the facts, the altercation during the survey, the subsequent prosecution initiated by the officer, the unexplained alteration of dates in the account books, repeated refusal to transfer the matter, the rejection of the adjournment request, and the making of best judgment assessments on substantially the same material together established personal bias. The statutory scheme did not compel only that officer to act, because other officers also had power to function as assessing authority and transfer of cases was permitted. The existence of an appellate remedy did not prevent interference where the order was vitiated by denial of justice and illegality going to jurisdiction.

Conclusion: The assessment orders were void for bias and were liable to be quashed. The objection based on alternative remedy failed.

Final Conclusion: The writ petition succeeded, and the consequential demand notices also fell with the quashed assessments.

Ratio Decidendi: A quasi-judicial assessment is invalid where facts objectively create a reasonable apprehension of personal bias, and such illegality can be corrected in writ jurisdiction notwithstanding the availability of an appellate remedy.

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