Writ jurisdiction and pending tax appeals: Article 226 relief was declined in favour of the statutory appellate process.

Where assessment orders are already under challenge in pending statutory appeals, writ relief under Article 226 is generally not entertained. The text explains that multiple assessment years require separate factual examination by the competent appellate authorities, and the existence of significant financial exposure does not by itself justify bypassing the ordinary appellate remedy. The practical effect is that parties who have already invoked the appellate mechanism should ordinarily pursue those remedies rather than seek quashing of the assessment orders through writ jurisdiction.

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Issues: Whether the writ petition under Article 226 of the Constitution of India should be entertained when assessment-related appeals were already pending before the statutory appellate authorities.

Analysis: The dispute involved multiple assessment years and the factual basis of each year required separate examination and findings by the statutory authorities. Since the petitioner had already availed the appellate remedy and the appeals were pending either before the Tribunal or the Sales Tax Commissioner, the Court held that it would not be to exercise writ jurisdiction to quash the assessment orders. The existence of large financial exposure by itself was held not to justify bypassing the regular appellate process.

Conclusion: The writ petition was not maintainable for interference under Article 226 in view of the pending statutory appeals, and the Court declined to exercise writ jurisdiction.

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