Writ jurisdiction cannot reopen a final tax assessment when the statutory appellate remedy was available.

Writ jurisdiction should not be used to reopen a tax assessment that has already attained finality, and the petitioner must ordinarily pursue the statutory appellate remedy under the Act. The assessment in question had been completed years earlier without departmental challenge and had become final; on that basis, the Court held that the writ petition was not maintainable to disturb the concluded assessment. Because the grievance could have been addressed through the prescribed appeal mechanism, the attempt to bypass that remedy was rejected, and the challenge to the final assessment failed.

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Issues: Whether a writ petition could be entertained to reopen and challenge a tax assessment that had already become final, and whether the petitioner was entitled to bypass the statutory appellate remedy.

Analysis: The assessment had been completed years earlier and had attained finality without any departmental appeal. The Court held that, as a matter of principle, writ jurisdiction should not be used to reopen concluded assessments. The petitioner ought to have pursued the appellate remedy provided under the Act for redress of the grievance, particularly when the amount had already been collected and the assessment had been allowed to become final.

Conclusion: The writ petition was not maintainable for reopening the final assessment and was rejected.

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