Alternative statutory remedy bars writ review where reassessment turns on disputed facts and no natural justice breach is shown.

Writ petitions challenging reassessment and penalty orders under the Tamil Nadu Value Added Tax Act were held not maintainable because an effective statutory appellate remedy was available. The dispute depended on contested facts, including the opening and shifting of godowns, alleged storage of goods in an unregistered place of business, and alleged suppression of turnover. As the petitioner had not filed objections to the revision notices despite opportunity, and no substantiated explanation was given for that omission, the case did not fall within recognised exceptions to the alternative-remedy rule, such as lack of jurisdiction or breach of natural justice. The merits were left open for the appellate authority.

---

---

Issues: Whether the writ petitions were maintainable in view of the alternative statutory appellate remedy under the Tamil Nadu Value Added Tax Act, 2006.

Analysis: The challenge to the reassessment and penalty orders turned on disputed questions of fact, including the date of opening and shifting of godowns, the alleged storage of goods in an unregistered place of business, and the alleged suppression of turnover. The petitioner had not filed objections to the revision notices despite opportunity, and the explanation for non-response was not substantiated. In such circumstances, the Court held that the case did not fall within the recognised exceptions to the rule of alternative remedy, such as total lack of jurisdiction or breach of natural justice. The Court declined to undertake fact-finding in writ jurisdiction and left the merits open to be urged before the appellate authority.

Conclusion: The writ petitions were not maintainable and were dismissed, with liberty to file statutory appeals within the time permitted by the Court.

---