Civil court jurisdiction barred where a special tax statute provides exclusive remedies for assessment, refund and correction.

The Tamil Nadu Agricultural Income Tax Act was treated as a self-contained code with its own machinery for assessment, refund, appeal, revision and rectification. Section 62 expressly barred civil suits to set aside or modify assessments under the Act, and the taxpayer's grievance that relevant material was ignored had to be pursued through the statutory remedies. Because the assessment was made under the Act and an express refund procedure existed, civil court jurisdiction was excluded by the statute. The suit was therefore not maintainable and the challenge had to proceed only under the Act.

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Issues: Whether the civil court had jurisdiction in view of section 62 of the Tamil Nadu Agricultural Income Tax Act, 1955, to entertain a suit challenging the assessment and seeking refund.

Analysis: The Act was treated as a self-contained code creating rights and liabilities and providing its own machinery for assessment, refund, appeal, revision, and rectification. Section 62 expressly barred suits to set aside or modify assessments made under the Act and barred proceedings against officers for acts done in good faith under the Act. Since the assessment itself was made under the Act, the grievance that relevant material was not considered could be pursued only through the statutory remedies and not by a civil suit. The availability of an express refund procedure and connected appellate and revisional remedies reinforced the exclusion of civil court jurisdiction.

Conclusion: The civil court had no jurisdiction, the suit was not maintainable, and the challenge had to be pursued only under the Act.

Ratio Decidendi: Where a special taxing statute creates the substantive liability and provides a complete and exclusive mechanism for assessment, refund and appellate correction, civil court jurisdiction is barred expressly or by necessary implication.

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