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Issues: (i) Whether the writ petition challenging the assessment orders was maintainable in view of the statutory appeal remedy. (ii) Whether a writ of mandamus could be issued to private respondents to compel supply of Form-C for enabling concessional tax treatment.
Issue (i): Whether the writ petition challenging the assessment orders was maintainable in view of the statutory appeal remedy.
Analysis: The assessment orders were passed under the tax laws governing the dispute, and the petitioner had an efficacious alternative remedy of appeal before the first appellate authority. In such circumstances, the writ court declined to interfere with the assessment orders on merits.
Conclusion: The challenge to the assessment orders was not entertained and relief was declined.
Issue (ii): Whether a writ of mandamus could be issued to private respondents to compel supply of Form-C for enabling concessional tax treatment.
Analysis: The entitlement to Form-C arose out of the contractual arrangement between the petitioner and the purchasing parties. The tax department was not a party to that contract, and a dispute over non-supply of Form-C could not be converted into a writ claim against private respondents. The proper recourse lay in enforcing the contractual remedy, including suit or arbitration, rather than invoking writ jurisdiction.
Conclusion: No mandamus could be issued to the private respondents to supply Form-C.
Final Conclusion: The writ petition failed in both respects and the court declined to grant any relief in exercise of writ jurisdiction.
Ratio Decidendi: Writ jurisdiction will not ordinarily be exercised to bypass an efficacious statutory appeal against assessment orders, and a mandamus cannot be issued to enforce a contractual obligation for issuance of Form-C when the appropriate remedy lies in contract enforcement.