Writ interference in revenue assessments declined where disputed facts on import or export sales required statutory appeal review.

Where a revenue assessment turns on disputed facts about the nature of duty-free shop sales under section 5(2) of the Central Sales Tax Act, 1956, the writ court will ordinarily decline interference if an adequate statutory appeal is available. The Court held that questions concerning delivery, movement of goods, and completion of the transaction required fuller factual examination and were better suited to the appellate authority. The existence of a legal issue did not, by itself, justify bypassing the statutory remedy. The writ petition was not entertained and the petitioner was relegated to the appellate forum.

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Issues: Whether the writ petition should be entertained despite the availability of an alternative statutory appeal, and whether the assessment on sales tax liability should be examined in writ jurisdiction.

Analysis: The dispute turned on whether the sales at the duty-free shops were sales in the course of import or export under section 5(2) of the Central Sales Tax Act, 1956. The assessment depended on facts concerning delivery, movement of goods, and the point at which the transaction was completed. The Court held that such questions required fuller factual examination and were better considered by the appellate authority. In revenue matters, where an adequate statutory remedy of appeal exists, writ interference is ordinarily unwarranted, and the availability of a pure question of law does not by itself justify bypassing the appellate forum.

Conclusion: The writ petition was not entertained and the petitioner was relegated to the statutory appeal remedy.

Ratio Decidendi: In revenue assessments involving disputed factual matrix, the presence of an adequate statutory appellate remedy normally bars writ interference, even where questions of law are also raised.

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