Writ challenge to entry tax notices failed where the dispute turned on a factual question for the statutory authority.

A writ petition challenging show-cause notices proposing entry tax was held premature because the central dispute was factual: whether goods were actually entering a local area for consumption, use or sale. That question required evidence and first-instance determination by the statutory authority, not review at the notice stage. The petitioner was expected to submit its defence before the Sales Tax Officer in reply to the notices. Writ jurisdiction was therefore declined, leaving the authority to decide the matter after hearing the petitioner.

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Issues: Whether a writ petition challenging show-cause notices proposing levy of entry tax was maintainable when the dispute turned on a factual question as to whether the petitioner was causing entry of goods into a local area.

Analysis: The challenge was directed only against notices issued under the relevant sales tax and entry tax provisions. The real controversy concerned whether goods were in fact entering another local area for consumption, use, or sale. That controversy was essentially factual and required examination of evidence by the statutory authority. The petitioner had an adequate opportunity to place its defence before the Sales Tax Officer in reply to the notices, and such matters could not properly be agitated in writ proceedings at the show-cause stage.

Conclusion: The writ petition was premature and not maintainable at that stage. The petitioner was required to respond to the notices and establish its case before the Sales Tax Officer.

Final Conclusion: Interference under writ jurisdiction was declined because the dispute had not yet reached a stage warranting judicial determination on the facts, and the statutory authority was left to decide the matter after hearing the petitioner.

Ratio Decidendi: A writ petition against a show-cause notice is not maintainable where the core dispute is a disputed question of fact that should first be determined by the statutory authority after considering evidence.

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