Premature writ challenge to reassessment notice declined where objections were pending and statutory remedy remained available.

Writ petitions challenging show cause notices and proposed reassessment under section 29(1) of the Madhya Pradesh Commercial Tax Act, 1994 were found premature because no final reassessment order had yet been passed. The taxpayer had already filed objections, and the statutory authority was still required to examine the facts and law before deciding the matter. As the controversy was only at the threshold stage and an effective statutory remedy remained available, the High Court declined to interfere under article 226. The petitions were therefore held not maintainable at that stage.

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Issues: Whether the writ petitions challenging the show cause notices and proposed reassessment proceedings under section 29(1) of the Madhya Pradesh Commercial Tax Act, 1994 were maintainable at the stage of notice.

Analysis: The notices only initiated reassessment and no final order had been passed. The petitioner had already submitted objections and the statutory authority was required to consider the matter on facts and law before taking a final decision. In such circumstances, the controversy was at the threshold stage, and the High Court declined to undertake fact-finding or interfere under article 226 of the Constitution of India when an effective statutory remedy remained available.

Conclusion: The writ petitions were premature and not maintainable at that stage; interference was declined.

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