Alternative statutory remedy bars Article 226 review of tax assessment; lack of detailed reasons alone is not a jurisdictional defect.

A writ petition under Article 226 was held inappropriate where the Income Tax Act provided a complete appellate mechanism and the assessee's own appeal was already pending; the existence of an adequate statutory remedy barred parallel writ intervention. The court also stated that an assessment order was not liable to certiorari merely because it did not set out detailed reasons or discuss the taxability of a receipt under Section 4(3)(vii) of the Travancore Income Tax Act. Absence of elaborate reasoning, by itself, did not show an error apparent on the face of the record or any want or excess of jurisdiction.

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Issues: (i) Whether a writ petition under Article 226 was maintainable against an assessment order when the Income Tax Act provided a complete appellate machinery and an appeal was already pending. (ii) Whether omission in the assessment order to give reasons or to discuss the taxability of the receipt under Section 4(3)(vii) of the Travancore Income Tax Act, 23 of 1121, rendered the order liable to certiorari.

Issue (i): Whether a writ petition under Article 226 was maintainable against an assessment order when the Income Tax Act provided a complete appellate machinery and an appeal was already pending.

Analysis: The statutory scheme afforded a full and effective remedy by appeal and further reference on questions of law. Where a complete machinery exists for deciding tax liability, resort to extraordinary writ jurisdiction is not available merely because the assessee is dissatisfied with the assessment. The pendency of the assessee's own appeal also weighed against parallel invocation of writ jurisdiction.

Conclusion: The writ petition was not maintainable on the ground of alternative statutory remedy and pending appeal.

Issue (ii): Whether omission in the assessment order to give reasons or to discuss the taxability of the receipt under Section 4(3)(vii) of the Travancore Income Tax Act, 23 of 1121, rendered the order liable to certiorari.

Analysis: The assessing officer was not shown to be under any legal duty to deliver a reasoned judgment discussing all pros and cons. The absence of detailed reasoning did not amount to an error apparent on the face of the record, nor did it show want or excess of jurisdiction. The assessment was therefore not vulnerable on that ground in certiorari.

Conclusion: The omission to record detailed reasons did not invalidate the assessment order.

Final Conclusion: The challenge to the assessment failed because the assessee had an adequate statutory remedy and no jurisdictional defect was established in the assessment order.

Ratio Decidendi: Where a taxing statute provides a complete and effective appellate remedy, the extraordinary writ jurisdiction will not be invoked to correct an allegedly erroneous assessment, and the mere absence of detailed reasons in the assessment order does not, by itself, constitute a jurisdictional defect.

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