Writ jurisdiction and tax exemption disputes: court declined interference, leaving coffee curing industries to pursue statutory appeals.

Writ jurisdiction was declined where coffee curing industries challenged an endorsement denying purchase-tax exemption, because the petitioners' entitlement under the industrial policy and the notification issued under the Karnataka Sales Tax Act was already the subject of pending statutory appeals. The impugned endorsement was treated as an administrative opinion or communication, not a determinative order justifying certiorari. The Court held that the proper forum for deciding the scope of the exemption notification and the assessee's entitlement was the appellate hierarchy, and it was inappropriate to examine the merits while the statutory remedy remained available. The writ petitions were therefore not entertained.

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Issues: Whether the writ petitions challenging the endorsement denying purchase-tax exemption benefits to coffee curing industries deserved interference in writ jurisdiction.

Analysis: The petitioners' entitlement to exemption under the industrial policy and the notification issued under section 19-C of the Karnataka Sales Tax Act, 1957 was already the subject of pending appellate proceedings under the statutory scheme. The endorsement impugned before the Court was treated as an opinion or communication and not as a determinative order warranting certiorari. The Court held that the proper forum for deciding the scope of the exemption notification and the petitioners' entitlement was the statutory appellate hierarchy, and it was inappropriate to pronounce on the merits of the controversy while appeals were pending.

Conclusion: The writ petitions were not entertained and no interference was called for.

Ratio Decidendi: Where an assessee's substantive tax entitlement can be agitated before the statutory appellate authorities, and the impugned communication is only an administrative opinion, the writ court should ordinarily decline to interfere and leave the parties to their statutory remedies.

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