Writ jurisdiction and disputed assessment facts: rectification remedy preferred where invoices and contract records need verification.

Disputed factual inconsistencies in the assessment orders, including the treatment of invoices and contractual arrangements, were held unsuitable for writ adjudication because they required verification of records and examination of the contractual scope. The availability of a statutory rectification mechanism under the Tamil Nadu Value Added Tax Act, 2006 supported relegation to that remedy, and the assessing authority was directed to reconsider the matter after hearing the petitioner, examining the documents, and, if necessary, calling for further details before passing a speaking order. The writ petitions were therefore not entertained on merits.

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Issues: Whether the impugned assessment orders warranted interference in writ jurisdiction when the challenge involved disputed factual errors, and whether the petitioner should be relegated to the statutory rectification remedy.

Analysis: The challenge turned on factual inconsistencies in the assessment orders, including the basis on which the invoices and contractual arrangements were appreciated. Such issues required verification of records and examination of the contractual scope, which was not appropriate for adjudication in writ proceedings. The Court noted that the State Act provided a mechanism for rectification of mistakes and that the petitioner could invoke that statutory remedy. The assessing authority was directed to consider the matter afresh after giving an opportunity of hearing, examining the documents, and, if necessary, calling for details from the second respondent before passing a speaking order.

Conclusion: The writ petitions were not entertained on merits and the petitioner was relegated to the statutory remedy under Section 84 of the Tamil Nadu Value Added Tax Act, 2006.

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