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Issues: Whether the writ petitions challenging the assessment orders were maintainable in view of the statutory appeal under section 31 of the Tamil Nadu General Sales Tax Act, 1959, where the controversy turned on disputed facts.
Analysis: The assessment orders were assailed on the ground of violation of natural justice, but the record showed that the petitioner had filed objections to the pre-assessment and revision notices. The dispute involved factual questions requiring examination of accounts and records. Section 31 of the Tamil Nadu General Sales Tax Act, 1959 provided an efficacious appellate remedy with power to confirm, reduce, enhance, annul, or set aside the assessment and direct fresh inquiry. In tax matters, where the statute provides a complete hierarchy of remedies and the facts are disputed, writ jurisdiction under article 226 is ordinarily not to be invoked.
Conclusion: The writ petitions were not maintainable and were dismissed, leaving the petitioner to pursue the statutory appeals.