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Issues: Whether the writ petitions challenging reassessment notices and orders under the Rajasthan Value Added Tax Act, 2003 were maintainable in view of the statutory appellate and revisional remedies, and whether the case fell within any exception to the rule of alternate remedy so as to permit direct invocation of Article 226 of the Constitution of India.
Analysis: The appeals arose from reassessment proceedings under the Rajasthan Value Added Tax Act, 2003, against which the statute provided a hierarchy of remedies by way of appeal and revision. The Court reiterated that the rule against entertaining a writ petition when an efficacious statutory remedy exists is a rule of self-imposed restraint, not an absolute bar, but exceptions are confined to cases of lack of jurisdiction, violation of natural justice, breach of fundamental rights, or similar exceptional circumstances. On the facts, the reassessment notices had been served, replies were considered, and the grievances related to the legality of reassessment and tax treatment of bundled goods, matters that could be agitated before the appellate forum. The Court found no inherent lack of jurisdiction or procedural unfairness of the kind that would justify bypassing the statutory mechanism. It also noted that similarly placed assessees had already pursued the statutory remedies and that authoritative consideration was pending before the Tax Board.
Conclusion: The writ petitions were not maintainable on the facts, and the appellants were required to pursue the statutory appeal and revision structure under the Act.
Final Conclusion: The challenge to the reassessment orders was left to the statutory forums, and the High Court declined to exercise writ jurisdiction in view of the efficacious alternative remedy available under the fiscal statute.
Ratio Decidendi: Where a fiscal statute provides an efficacious appellate and revisional remedy, the High Court will ordinarily not entertain a writ petition unless the case discloses inherent lack of jurisdiction, breach of natural justice, or another established exception to the rule of alternate remedy.