Writ jurisdiction and best judgment assessments: statutory appeal must usually be exhausted before High Court intervention.

Writ jurisdiction under Article 226 is ordinarily not exercised against best judgment assessment orders where an efficacious statutory appeal exists. The Gauhati High Court reiterated that interference is justified only on proof of jurisdictional error or a substantial breach of natural justice, not for reappreciation of facts or merits of the assessment. On the facts noted, the assessees failed to produce C forms in time and did not adequately pursue the matter before the assessing authority, so no complete denial of hearing or procedural illegality was established. The matter was therefore treated as one for the appellate forum under the sales tax law.

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Issues: Whether the writ jurisdiction under Article 226 of the Constitution of India should be exercised to interfere with best judgment assessment orders under the sales tax law when an efficacious alternative appellate remedy was available and the assessees alleged violation of natural justice.

Analysis: The petitioners were registered dealers and claimed exemption from tax on inter-State sales on the strength of C forms, but they failed to produce the required declarations within time and did not pursue the matter before the assessing authority after seeking adjournment. The assessment was therefore made on best judgment basis. The Court held that the conduct of the assessees showed disregard of the statutory process and that no procedural illegality or complete denial of hearing was established. It reiterated that writ jurisdiction is ordinarily not invoked where an efficacious statutory appeal exists, and interference is justified only in cases of want of jurisdiction or grave violation of natural justice. The Court further noted that judicial review does not extend to reappreciation of facts or correctness of the assessment on merits.

Conclusion: The writ petitions were not maintainable for bypassing the statutory appellate remedy and no interference with the assessment orders was warranted under Article 226.

Final Conclusion: The assessees were directed to pursue the appellate forum under the sales tax law, with temporary protection against coercive recovery for the stated period.

Ratio Decidendi: An efficacious statutory alternative remedy must ordinarily be exhausted before invoking writ jurisdiction, and judicial review will not interfere with a best judgment assessment absent jurisdictional error or a substantial breach of natural justice.

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