Writ jurisdiction and statutory appeal: factual findings in an assessment order must be challenged through the appellate remedy.

Where an assessment order rests on factual findings such as invoice genuineness and the nature of transactions, the High Court declined to reappreciate those matters in writ jurisdiction. It held that the petitioner had to challenge such findings through the statutory appellate remedy, and the availability of an effective appeal weighed against writ interference. The writ petition was therefore not entertained, and the petitioner was left to pursue the appeal against the assessment order.

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Issues: Whether the writ petition challenging the assessment order was maintainable in view of the available appellate remedy.

Analysis: The impugned order was based on factual findings recorded by the assessing authority, including the genuineness of the invoices and the nature of the transactions. The Court declined to examine the merits of those findings in writ jurisdiction and held that the petitioner had to question them in a properly constituted appeal. The existence of an effective appellate remedy weighed against interference under writ jurisdiction.

Conclusion: The writ petition was not entertained and was dismissed, leaving the petitioner to pursue the statutory appeal against the assessment order.

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