Writ jurisdiction and disputed tax facts cannot bypass an effective statutory appeal under sales tax law.

Writ jurisdiction was held unsuitable for challenging an assessment where the central dispute turned on disputed facts about whether the dealer was carrying on a printing business or merely selling printed materials obtained through job-work. Section 3G of the Tamil Nadu General Sales Tax Act, 1959 grants compounded tax at three per cent only to a dealer carrying on printing business, and that entitlement required factual scrutiny already within the assessing authority's record. Because an effective statutory appeal was available under section 31, and there was no patent lack of jurisdiction or manifest illegality, Article 226 relief was not invoked to bypass the appellate remedy; the challenge to the assessment failed.

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Issues: Whether the assessee could invoke writ jurisdiction to challenge the assessment and claim the benefit of compounded tax under section 3G of the Tamil Nadu General Sales Tax Act, 1959, when the dispute turned on factual questions and a statutory appeal was available.

Analysis: Section 3G confers an option to a dealer carrying on the business of printing to pay tax at the compounded rate of three per cent on total turnover. The dispute in the present case depended on whether the assessee was engaged in printing business or only in selling printed materials obtained through job-work. That question required examination of facts and materials already considered by the assessing authority. Where an effective appellate remedy exists under section 31 of the Tamil Nadu General Sales Tax Act, 1959, writ jurisdiction is not to be used to bypass that remedy. In the absence of a patent lack of jurisdiction or manifest illegality in the assessment order, the High Court would not interfere under Article 226 of the Constitution of India.

Conclusion: The writ petition was not maintainable and the challenge to the assessment was rejected in favour of the Revenue.

Ratio Decidendi: Writ jurisdiction should not be invoked to decide disputed questions of fact or to bypass an efficacious statutory appeal, unless the impugned order is patently without jurisdiction or illegal.

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