Alternate statutory remedy barred writ review where rectification challenge required factual re-appreciation and not a pure legal issue.

Writ jurisdiction was treated as unavailable where the challenge to rejection of rectification applications required factual re-appreciation of deemed assessments and the correctness of the materials relied upon. The availability of an effective statutory revision before the Joint Commissioner was held to provide an efficacious alternate remedy under the fiscal statute. In such a hierarchy of remedies, the court declined to let the writ petitions bypass the prescribed revisional course, especially because the plea of error apparent on the face of the record did not arise as a pure question of law. The writ petitions were held not maintainable and dismissed.

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Issues: Whether the writ petitions were maintainable when an efficacious revisional remedy was available under the tax statute.

Analysis: The challenge to the rejection of rectification applications was not confined to a pure question of law, but involved appreciation of facts and the correctness of the materials relied upon for the deemed assessments. The availability of a statutory revision before the Joint Commissioner provided an effective and efficacious alternate remedy. In a matter arising under a fiscal enactment with a prescribed hierarchy of remedies, the writ jurisdiction was not to be invoked to bypass that statutory course, particularly where the dispute required factual re-appreciation and the plea of error apparent on the face of the record could not be examined as a simple legal issue.

Conclusion: The writ petitions were held to be not maintainable and were dismissed.

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