Alternative statutory remedies bar writ relief against provisional attachment and VAT recovery notices when assessment notices are ignored

Writ jurisdiction was considered unavailable where taxpayers challenged provisional attachment, bank account freezing and recovery notices under the VAT Act while ignoring repeated statutory notices to produce records and attend assessment. The statutory scheme provided provisional assessment, revenue-protective attachment and third-party recovery measures, and also supplied appeal and revision remedies. Because those remedies were available and the petitioners had not cooperated with the assessment process, the court declined to bypass the statutory framework under Article 226. The challenge to the impugned notices and provisional attachment therefore failed and the writ petitions were not entertained.

---

---

Issues: Whether the writ petitions challenging provisional attachment, bank account freezing and notices issued under the VAT Act were maintainable despite the petitioners' failure to comply with statutory notices and availability of alternative statutory remedies.

Analysis: Repeated notices had been issued calling upon the petitioners to produce records and remain present for assessment, but they failed to comply. The statutory scheme permitted provisional assessment, provisional attachment to protect revenue, and recovery measures including notices to third parties. Since appeal and revision remedies were available under the Act, the petitioners could not bypass the statutory framework and directly invoke writ jurisdiction. Their non-cooperative conduct also disentitled them to discretionary relief under Article 226.

Conclusion: The challenge to the impugned notices and provisional attachment failed, and the writ petitions were not entertained.

---