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Issues: Whether the writ appeal should be entertained against the Single Judge's decision relegating the assessee to the statutory appellate remedy, in the face of objections based on alleged breach of natural justice and the availability of alternate remedy.
Analysis: The statutory appellate remedy was held to be the proper forum for examining the assessee's objections, including alleged breach of natural justice and reliance on the Commissioner's circular. The rule of alternate remedy was treated as a rule of discretion, not a bar, and writ jurisdiction was held to be exercisable only in exceptional cases such as challenge to vires, gross breach of natural justice, or patent lack of jurisdiction. Since the assessee could raise all such grounds before the appellate authority, interference with the Single Judge's order was found unwarranted.
Conclusion: The writ appeal was not maintainable on merits and the order relegating the assessee to the first appellate authority was upheld.