Writ remedy and disputed tax facts: appellate forum is the proper place to test assessment objections.

A writ challenge to an assessment order under the Tamil Nadu Value Added Tax Act was not entertained because the grievance depended on disputed factual questions, including alleged denial of personal hearing and the treatment of invoices. The court treated the statutory appeal as the proper forum for fact-finding and for examining those objections, especially where the petitioner had already been heard in a prior Section 84 process. The petitioner was therefore directed to pursue the appellate remedy instead of seeking writ relief.

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Issues: Whether the writ petition challenging the assessment order and the consequential proceedings should be entertained when the grievance turned on disputed factual issues and the petitioner had an appellate remedy.

Analysis: The dispute arose out of assessment proceedings under the Tamil Nadu Value Added Tax Act, 2006, after the petitioner had already been permitted to pursue a petition under Section 84 and had been heard in that process. The objections raised in the writ petition related chiefly to factual aspects, including alleged denial of personal hearing and the treatment of invoices referred to in the assessment order. Such matters were held to be appropriate for examination by the appellate forum, which is the proper fact-finding authority.

Conclusion: The writ petition was not entertained on merits and the petitioner was relegated to the statutory appellate remedy.

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