Writ jurisdiction and Form-C concessional tax claim must be assessed on the full documentary record, not a single endorsement.

Disputed documentary questions arising from invoices, a tripartite arrangement and the lorry way bill required factual verification, so writ jurisdiction was not the proper forum and the assessee had to pursue the statutory appellate remedy. The appellate authority was also required to consider the Form-C based concessional tax claim independently on the basis of the entire transaction and supporting documents, rather than relying only on a single endorsement in the lorry way bill. The appeal was disposed of with protection against coercive recovery pending the statutory appeal and directions for independent appellate adjudication on the tax benefit claim.

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Issues: (i) Whether the writ court was justified in relegating the assessee to the statutory appellate remedy instead of entertaining the challenge to the assessment order; (ii) Whether the assessee's claim for concessional tax benefit on the basis of Form-C declaration required independent consideration on the totality of the transaction and supporting documents.

Issue (i): Whether the writ court was justified in relegating the assessee to the statutory appellate remedy instead of entertaining the challenge to the assessment order.

Analysis: The assessment involved disputed questions arising from invoices, tripartite arrangements and the lorry way bill, which required appreciation of documents and factual verification. Such an exercise could not be undertaken in writ proceedings, and the statutory appellate forum was the proper authority to examine the matter independently.

Conclusion: The writ court's decision to relegate the assessee to the appellate remedy was upheld.

Issue (ii): Whether the assessee's claim for concessional tax benefit on the basis of Form-C declaration required independent consideration on the totality of the transaction and supporting documents.

Analysis: The Court found that the Assessing Officer had placed undue reliance on a single endorsement in the lorry way bill, while the invoices and contractual documents suggested a broader transactional context. The Appellate Authority was therefore required to examine all documents independently and determine whether the Form-C declaration could be accepted.

Conclusion: The Appellate Authority was directed to decide the assessee's claim independently and, if satisfied, extend the Form-C benefit.

Final Conclusion: The appeal was disposed of while leaving the assessee to pursue the statutory appeal, with protection against coercive recovery in the meantime and directions for independent appellate adjudication on the tax claim.

Ratio Decidendi: Where determination of concessional sales tax entitlement turns on disputed documents and factual appreciation, writ jurisdiction should not be used to bypass the statutory appellate process, and the appellate authority must decide the issue independently on the entire material.

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