Writ jurisdiction cannot be used to bypass reassessment and appeal remedies for a collateral challenge to approval records.

Where an assessee has effective statutory remedies in reassessment proceedings and in appeal, the writ court will not entertain a collateral request for production of an alleged approval letter or other relief that would bypass the statutory process. The court noted that the challenge to the notice was not pressed, and the remaining issues concerning approval of the superannuation scheme, its tax consequences, and the reopening grounds could be pursued before the reassessment authority and in the pending appeal. On that basis, writ jurisdiction was declined and no relief was granted.

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Issues: Whether the petitioner was entitled, in writ jurisdiction, to a direction for production of the approval letter and related relief when reassessment proceedings were pending and an appeal against the assessment order was already available.

Analysis: The petitioner had not pressed the challenge to the notice itself, and the remaining request sought only a direction for production of an alleged approval letter. The Court noted that the dispute concerning approval of the superannuation scheme, its tax consequences, and the grounds arising from the reopening notice and the assessment order could be pursued in the reassessment proceedings and the pending appeal. In these circumstances, the writ court would not grant the requested relief or permit the petitioner to bypass the statutory process.

Conclusion: The petitioner was not entitled to relief in writ jurisdiction, and the petition failed.

Ratio Decidendi: Where an assessee has effective statutory remedies in reassessment and appeal, the writ court will not entertain a misconceived collateral challenge seeking to bypass those remedies.

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