Writ jurisdiction and alternate remedy: High Court declined interference where statutory revision was time-barred and objections were considered.

A writ petition challenging a revenue demand under the Tamil Nadu Value Added Tax Act, 2006 was rejected because the assessee had an efficacious statutory revision remedy under Section 54, and that remedy was already time-barred when the writ was filed. The Court also found no violation of natural justice, since the impugned order expressly considered the assessee's objection and reply and gave reasons for rejecting the requested adjustment of tax paid towards stock deficit. In these circumstances, interference under Article 226 was declined and the revenue action was left undisturbed.

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Issues: Whether the writ petition was liable to be entertained despite the availability of a statutory revision under the Tamil Nadu Value Added Tax Act, 2006 and the bar of limitation, and whether non-consideration of the petitioner's reply amounted to violation of natural justice warranting interference under Article 226 of the Constitution of India.

Analysis: The impugned order showed that the petitioner's objection and reply were expressly considered and rejected on merits. The Court held that the grievance of violation of natural justice was not made out, since the authority had dealt with the reply and given reasons for disallowing adjustment of the tax paid towards stock deficit. The Court further held that the petitioner had an alternate statutory remedy of revision under Section 54 of the Tamil Nadu Value Added Tax Act, 2006, which was already barred by limitation when the writ petition was filed. In such circumstances, interference in writ jurisdiction was not justified.

Conclusion: The writ petition was not entertainable and the challenge to the impugned order failed.

Final Conclusion: The Court declined to exercise writ jurisdiction and upheld the revenue action, leaving the statutory demand undisturbed.

Ratio Decidendi: Where an efficacious statutory remedy exists and is time-barred, and the impugned order has in fact considered the assessee's objections, the writ court will not interfere under Article 226 of the Constitution of India on a bare plea of violation of natural justice.

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