Writ of prohibition refused where revision notice on completed assessment was within jurisdiction and factual objections had to be pursued statutorily.

A writ of prohibition was unavailable to restrain revision proceedings against a completed assessment under the Tamil Nadu General Sales Tax Act, 1959, because the assessing officer's notice was within jurisdiction. The objections concerning the Section 7(C) option and treatment of works contract turnover raised factual questions requiring adjudication on merits. The proper course was to file objections before the assessing authority and pursue the statutory process rather than seek prohibition against the proceedings.

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Issues: Whether a writ of prohibition could be issued to restrain the assessing authority from proceeding with notice for revision of a completed assessment under the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The notice to revise a completed assessment was within the authority of the assessing officer and therefore was not without jurisdiction. The objections raised by the petitioner, including the claimed option under Section 7(C) and the treatment of the works contract turnover, involved factual enquiry and adjudication on merits. In such circumstances, the petitioner was required to submit objections before the assessing authority rather than seek prohibition against the proceedings.

Conclusion: The writ of prohibition was not granted and the petitioner was directed to pursue the statutory objection process before the respondent.

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