Best judgment tax assessment and disputed facts were left to the statutory appeal, with no writ interference for natural justice breach.

Disputed factual questions in a best judgment tax assessment, including issues on closing stock and alleged sales suppression, were held unsuitable for writ interference under Article 226 when the assessee had received notice and an opportunity to reply. The court found no clear denial of fair hearing or breach of natural justice, so the assessment order was left undisturbed. Liberty was preserved to pursue the statutory appeal, and interim recovery was kept in abeyance for a limited period.

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Issues: Whether the assessment order passed under best judgment required interference in writ jurisdiction on the ground of non-compliance with the appellate direction and violation of natural justice.

Analysis: The assessment was made in the second round after notice and consideration of the reply. The factual dispute centred on the closing stock and alleged sales suppression, which required appreciation of evidence and enquiry into facts. Such matters were better left to the statutory appellate forum. On the materials placed, the Court found no basis to hold that the assessee had been denied a fair opportunity or that principles of natural justice were violated.

Conclusion: Interference under Article 226 was not warranted, and the assessment order was left undisturbed.

Final Conclusion: The writ petition did not succeed on merits, though liberty was preserved to pursue the statutory appeal and interim recovery was kept in abeyance for a limited period.

Ratio Decidendi: Disputed questions of fact arising from a best judgment tax assessment, when considered after notice and reply, are ordinarily not amenable to interference in writ jurisdiction absent a clear violation of natural justice.

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