Efficacious statutory appeal bars writ challenge where reassessment dispute turns on contested facts and no jurisdictional defect exists.

Writ jurisdiction under Article 226 was declined because the reassessment challenge involved disputed factual questions on the nature of the contract, transfer of property in goods, and deductions or exemptions, all of which could be examined in the statutory appeal under Section 62 of the Karnataka Value Added Tax Act. The Court found no allegation of vires, jurisdictional defect, or fundamental procedural illegality, and noted that the assessee had already participated in the assessment proceedings and sought rectification. The existence of an efficacious appellate remedy therefore weighed against writ interference, and the petitions were dismissed.

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Issues: Whether the writ petitions challenging the reassessment order were maintainable in view of the statutory appellate remedy under Section 62 of the Karnataka Value Added Tax Act.

Analysis: The challenge turned on disputed facts regarding the nature of the contract, the extent of transfer of property in goods, and the availability of deductions and exemptions. The assessment had already been completed after notice, the petitioner had participated in the proceedings, and the rectification request had also been rejected. The Court found that no challenge to the vires of the statute or to any jurisdictional defect or fundamental procedural illegality was involved. Such factual and legal disputes could be effectively examined by the appellate authority, and the existence of an efficacious statutory remedy weighed against exercise of writ jurisdiction under Article 226 of the Constitution of India.

Conclusion: The writ petitions were not maintainable and had to be dismissed in favour of the Revenue.

Ratio Decidendi: Where an efficacious statutory appeal is available and the controversy involves disputed factual issues rather than a challenge to jurisdiction or the validity of the statute, writ jurisdiction should ordinarily not be exercised.

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