Writ jurisdiction in sales tax assessment disputes is normally refused when statutory appeals and revision provide an adequate remedy.

The Karnataka HC declined to exercise writ jurisdiction against a sales tax assessment under the Karnataka Sales Tax Act, 1957 because the dispute concerned the treatment of turnover, deductions for export and inter-State sales, and whether goods were exported outside the State, all of which could be examined on facts and evidence in the statutory appeal. The Act provided an efficacious appellate and revisional hierarchy, including further appeal, second appeal to the Tribunal, and revision to the High Court. No inherent lack of jurisdiction in the assessing authority was shown, so Article 226 relief was refused and the jurisdictional objection failed.

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Issues: Whether the writ petition challenging the sales tax assessment order was maintainable in view of the available statutory appellate and revisional remedies, and whether the assessing authority lacked inherent jurisdiction to make the impugned levy.

Analysis: The assessment order under the Karnataka Sales Tax Act, 1957, related to turnover on which tax was levied after allowing deductions for export sales and inter-State sales. The challenge was essentially directed to the manner in which the assessing authority treated the remaining turnover and to the allegation that the goods had been exported outside the State. That dispute turned on facts and evidence already before the assessing authority and could be examined in the statutory appeal. The Act also provided a further appeal, a second appeal to the Tribunal, and revision to the High Court, making the statutory scheme an efficacious alternative to writ intervention. No inherent lack of jurisdiction in the assessing authority was shown.

Conclusion: The writ court declined interference under Article 226 because the petitioner had not exhausted the available statutory remedies, and the jurisdictional objection failed.

Ratio Decidendi: Where an assessment is challenged on factual or legal grounds within a comprehensive statutory appellate structure, writ jurisdiction will not ordinarily be exercised in the absence of demonstrated inherent lack of jurisdiction or exceptional circumstances.

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