Statutory appeal bars writ challenge to tax assessment orders where factual and procedural issues remain unresolved.

Where a final tax assessment order is challengeable by an effective statutory appeal, writ jurisdiction under Article 226 should ordinarily not be invoked. Issues concerning the correctness of assessment, opportunity of hearing, supply of documents, and other factual objections are better examined by the appellate authority under Section 61 of the M.P. Commercial Tax Act, 2002. Any grievance regarding pre-deposit may also be pursued before the competent authority in accordance with law. The writ petitions were therefore not maintainable, and the assessees were relegated to the statutory appellate forum without merits adjudication.

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Issues: Whether the writ petitions challenging the assessment orders were maintainable when an efficacious statutory appeal was available under the M.P. Commercial Tax Act, 2002.

Analysis: The assessment proceedings had culminated in final orders, and the challenge raised questions relating to the correctness of assessment, opportunity of hearing, supply of documents, and other factual matters. These issues were held to be more appropriately examinable by the statutory appellate authority under Section 61 of the M.P. Commercial Tax Act, 2002. The availability of an independent appellate remedy rendered exercise of extraordinary writ jurisdiction under Article 226 inappropriate. Any grievance concerning pre-deposit could also be pursued before the competent authority in accordance with law.

Conclusion: The writ petitions were not maintainable and no interference was warranted in writ jurisdiction; the petitioner was required to pursue the statutory appeal.

Final Conclusion: The challenge to the assessment orders was relegated to the statutory appellate forum, and the writ petitions were disposed of without adjudication on the merits of the assessment.

Ratio Decidendi: Where an effective statutory appeal exists against a final tax assessment order, the writ court should ordinarily decline interference under Article 226, especially on issues involving factual appraisal and procedural objections.

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