Writ relief barred by statutory appeal in fiscal matters where mismatch precedent was factually inapplicable.

Writ jurisdiction is ordinarily declined in fiscal matters where an effective statutory appellate remedy is available, and that restraint applies with greater rigour under the Tamil Nadu VAT regime. The Court held that the earlier mismatch precedent did not assist the assessee because it concerned a discrepancy between dealer returns and departmental data, whereas the present dispute involved differences between two returns filed by the same assessee. On that factual distinction, the precedent was inapplicable, and the assessee was directed to pursue the statutory appeal with liberty to seek consequential relief before the appellate authority.

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Issues: Whether the impugned revised assessment proceedings could be interfered with in writ jurisdiction despite the availability of a statutory appeal under the Tamil Nadu Value Added Tax Act, 2006.

Analysis: The writ challenge was based on the contention that the assessment was vitiated by a mismatch principle recognised in earlier case law. The Court found that the earlier decision concerned a mismatch between the dealer's returns and departmental data, whereas the present matter involved discrepancies between two sets of returns filed by the same dealer. On that factual distinction, the cited precedent was held inapplicable. The Court further applied the settled rule that writ jurisdiction is ordinarily not exercised where an effective statutory remedy exists, and that this restraint applies with greater rigour in fiscal matters. Since an appeal lay under the statute, the petitioner was directed to pursue that remedy, with liberty to seek consequential reliefs before the appellate authority.

Conclusion: The writ petition was not maintainable on merits in view of the available statutory appeal, and the challenge to the impugned proceedings failed.

Ratio Decidendi: In fiscal matters, writ relief is ordinarily declined where an effective statutory appellate remedy is available, and a precedent based on a mismatch between departmental data and dealer returns does not apply where the dispute is between two returns filed by the same assessee.

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