Statutory appellate remedy bars writ review of tax assessment disputes involving factual valuation and penalty issues.

Writ jurisdiction was declined against notices that had culminated in assessment orders under the Rajasthan Value Added Tax Act, 2003 because an efficacious statutory appeal was available. The challenge was not limited to the legality of the notices but extended to valuation of accessories, interest and penalty, all of which required factual adjudication by the appellate forum. In tax matters, where the dispute is not purely jurisdictional and can be examined under the statutory scheme, Article 226 relief is ordinarily not entertained. The petitioners were left to pursue the prescribed appellate remedy.

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Issues: Whether the writ petitions challenging notices issued under the Rajasthan Value Added Tax Act, 2003 and the consequential assessment orders were maintainable in view of the statutory appellate remedy.

Analysis: The notices under the Act had culminated in assessment orders, and the challenges raised by the petitioners were not confined to the legality of the notices alone but extended to valuation of accessories, interest and penalty, which involved factual determination. The statutory scheme provided an appellate remedy against the assessment orders, and the Court held that such grievances ought to be pursued before the prescribed appellate forum rather than in writ jurisdiction. In tax matters, where the dispute can be examined by the statutory authority and the issues are not purely jurisdictional, the existence of an efficacious alternative remedy weighs against interference under Article 226 of the Constitution of India.

Conclusion: The challenge to the notices and assessment orders was not entertained in writ jurisdiction, and the petitioners were left to pursue the statutory appeal.

Final Conclusion: The writ petitions were dismissed, with liberty to the petitioners to seek redress before the appellate authority in accordance with law.

Ratio Decidendi: Where a tax statute provides an efficacious appellate mechanism, the High Court will ordinarily not exercise writ jurisdiction to re-examine assessment-related disputes, especially when the controversy involves factual issues fit for statutory adjudication.

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