Alternative appellate remedy bars writ review where tax disputes involve mixed questions of fact and law.

Where a reassessment revision under the Karnataka Value Added Tax Act raised mixed questions of fact and law concerning works execution, tax deduction, and credit entitlement, writ jurisdiction was held inappropriate because an efficacious statutory appellate remedy was available. The Court treated the availability of that alternative remedy as decisive for declining merits-based writ scrutiny, and the petition was dismissed with liberty to pursue the appellate route.

---

---

Issues: Whether the writ petition was maintainable against the impugned reassessment revision order when an efficacious alternative appellate remedy was available under the Karnataka Value Added Tax Act, 2003, particularly where the dispute involved mixed questions of fact and law.

Analysis: The challenge arose from a reassessment revision concerning tax liability of a sub-contractor and the claimed adjustment of tax allegedly deducted in the hands of the main contractor. The controversy depended on the factual matrix relating to execution of works, deductions, returns, and entitlement to credit under the KVAT framework. Since the matter required examination of facts as well as the applicable statutory scheme, and the legislature had provided an effective appellate mechanism for such adjudication, the extraordinary writ jurisdiction was held to be inappropriate for examining the dispute on merits.

Conclusion: The writ petition was not maintainable in view of the alternative and efficacious remedy of appeal, and the petition was dismissed with liberty to pursue that remedy.

Ratio Decidendi: Where the dispute raises mixed questions of fact and law and the statute provides an efficacious appellate remedy, the Court will ordinarily decline to exercise writ jurisdiction.

---