Finality of tax assessment bars writ reopening; later judgment cannot revive concluded liability.

A writ petition cannot be used to reopen a tax assessment that has already attained finality, especially where the assessee did not pursue the statutory revision and tax was paid under the appellate order. A later judicial pronouncement does not, by itself, revive a concluded liability or justify writ interference. The court also noted that the later Supreme Court decision did not address the specific issue under section 7-A(1)(c), and the goods were found to be machinery rather than iron scrap. The writ petitions were therefore held not maintainable against the concluded assessment.

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Issues: Whether the writ petitions could be entertained after the assessment order had attained finality and the petitioner had not pursued the statutory revision, and whether a subsequent judicial pronouncement could reopen the concluded tax liability.

Analysis: The assessment and appellate orders had not been challenged by the prescribed further revision under section 38 of the Tamil Nadu General Sales Tax Act, 1959, and the tax had already been paid pursuant to the appellate order. In that situation, the dispute was concluded and the petitioner could not invoke writ jurisdiction merely because a later judgment was said to support a different view. A subsequent change in law does not, by itself, revive a cause that has already attained finality. The Court also noted that the later Supreme Court decision did not decide the specific question under section 7-A(1)(c) and, in any event, the goods were found to be machinery and not iron scrap.

Conclusion: The writ petitions were not maintainable against a concluded assessment and were decided against the assessee.

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