Writ maintainability in tax assessment disputes depends on direct cause of action, not challenge to internal circulars.

Assessment under the Tamil Nadu General Sales Tax Act, 1959 must follow the statute and cannot be controlled by an internal circular, but a traders' association lacking a direct cause of action cannot invoke writ jurisdiction merely to challenge such departmental correspondence. The statutory scheme contemplated prior notice of the proposed assessment and an opportunity to object, so any grievance against an assessment alleged to be contrary to law could be pursued before the appropriate authority. On that basis, the writ petition challenging the circular and proposed assessment was held not maintainable and was dismissed.

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Issues: Whether the writ petition filed by the traders' association challenging the circular and the proposed assessment under the Tamil Nadu General Sales Tax Act, 1959 was maintainable in the absence of a direct cause of action.

Analysis: The dispute arose from assessments relating to sales of ball bearings under forms XVII and the departmental view that section 3(5) of the Tamil Nadu General Sales Tax Act, 1959 could be applied. The challenge was directed against an internal circular and the association sought to question the legality of that circular on behalf of its members. The governing principle applied was that assessment must be made according to the statute and not according to any circular, but an association, without a direct cause of action, cannot invoke writ jurisdiction merely to question such internal departmental correspondence. The statutory scheme also provided safeguards, including prior notice of proposal and opportunity to file objections, and any grievance against an assessment made contrary to law could be pursued before the appropriate authority.

Conclusion: The writ petition was not maintainable and was dismissed.

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