Statutory appeal limitation bars writ challenge, while rectification remains available if otherwise permitted by law.

A writ challenge to a statutory assessment order was not entertained because the assessee had not filed the statutory appeal within the maximum limitation period, including the limited scope for condonation under the Tamil Nadu Value Added Tax Act, 2006. The Court applied the settled principle that Article 226 jurisdiction should not be used to bypass an available appellate remedy that was not pursued in time, and the challenge was rejected. It left open, however, the assessee's ability to seek rectification of the assessment order under the rectification provision, if such relief was otherwise available in law, without expressing any view on the merits.

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Issues: Whether a writ petition challenging a statutory assessment order was maintainable when the petitioner had not filed the statutory appeal within the maximum period of limitation, and whether the petitioner could still seek rectification under the rectification provision.

Analysis: The assessment order was appealable under the Tamil Nadu Value Added Tax Act, 2006 within the prescribed period, with only a limited further period available for condonation of delay. The writ petition was filed beyond the maximum permissible appellate period. In view of the settled principle governing writ jurisdiction under Article 226 of the Constitution of India, the Court declined to entertain a challenge to an order that had not been pursued through the statutory appellate remedy within limitation. The Court also kept open the petitioner's right, if otherwise available in law, to seek rectification of the impugned order under the rectification provision, without expressing any view on the merits of such claim.

Conclusion: The writ petition was not maintainable against the unappealed assessment order filed beyond the maximum limitation period, and the challenge was rejected. The petitioner was left at liberty, if otherwise entitled, to pursue rectification in accordance with law.

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