Statutory appellate remedy preferred over writ review, with interim protection against recovery granted pending appeals.

A writ challenge to an assessment order and refund rejection was declined because the dispute required factual examination better suited to the statutory appellate authority. The court held that the presence of a prima facie case did not justify bypassing the efficacious appellate remedy, so the appellant was relegated to that remedy instead of obtaining merits review in writ jurisdiction. Considering the special circumstances, however, the court granted time to file appeals and protected the disputed recovery until the appeals were decided expeditiously.

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Issues: Whether the assessment order and refund rejection warranted interference in writ jurisdiction, or whether the appellant should be relegated to the statutory appellate remedy with interim protection.

Analysis: The assessment was challenged on the ground of non-consideration of objections and perversity, but the Court found that the controversy required factual examination better suited to the appellate authority. The existence of a prima facie case did not justify bypassing the statutory remedy, which was treated as efficacious. At the same time, considering the special circumstances, the Court granted time to file appeals and protected the disputed recovery until the appeals were decided expeditiously.

Conclusion: The writ challenge was not entertained on merits, the appellant was relegated to the statutory appeal remedy, and interim protection against recovery was granted till disposal of the appeals.

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