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Issues: Whether the writ petition under Article 226 was maintainable in view of the statutory remedies of appeal and revision under the Rajasthan Sales Tax Act, 1994.
Analysis: The assessment orders were appealable under the statutory scheme, with a first appeal, second appeal, and revision available. The Court treated the right of appeal as a substantive remedy and held that writ jurisdiction should ordinarily not be invoked where an alternative and equally efficacious remedy exists. The dispute involved factual and mixed questions, including entitlement to exemption, whether the petitioner's activity amounted to manufacture, and whether the assessing authority had followed the relevant notifications and law. No exceptional ground such as patent lack of jurisdiction, violation of natural justice, or other recognized exception to the rule against bypassing alternate remedies was found.
Conclusion: The writ petition was not maintainable and was dismissed on the ground of availability of an alternative remedy.
Ratio Decidendi: Where an adequate and efficacious statutory remedy of appeal or revision is available and no exceptional ground exists, the High Court should decline to exercise writ jurisdiction under Article 226.