Alternate remedy limits writ interference with assessment orders; disputed taxability and factual issues go to the appellate forum.

Availability of an effective alternate appellate remedy ordinarily weighs against writ interference with an appealable assessment order, even where breach of natural justice is alleged. The Madras HC noted that no exceptional circumstance, such as lack of jurisdiction, was shown, and that the grievance could be raised before the appellate authority. It also declined to examine disputed questions relating to Section 63A, the taxability of UPS, and the corrigendum to Form WW, because those matters involved factual and evidentiary issues and a rectification application was already pending before the assessing authority. The assessee was relegated to the appellate forum, and the rectification request was to be decided expeditiously.

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Issues: Whether the intra-court appeals challenging assessment orders were liable to be interfered with when an effective alternate remedy before the appellate authority was available, and the appellant also relied on alleged breach of natural justice and the corrigendum to Form WW.

Analysis: The Court held that availability of an alternate remedy is not an absolute bar to writ jurisdiction, but it is a well-recognised rule of discretion. The assessment orders were appealable, no case of lack of jurisdiction or other exceptional circumstance was made out, and the grievance based on breach of natural justice could be urged before the appellate authority. The Court also declined to pronounce on the interpretation of Section 63A or on the taxability of UPS, as both matters involved factual and evidentiary questions and the rectification application had already been filed before the assessing authority. The request regarding Form WW and supporting documents was left to be considered by the appellate forum, and the rectification application was directed to be decided expeditiously.

Conclusion: The Court refused to interfere with the assessment orders and relegated the assessee to the appellate remedy; the appeals were rejected on the ground of alternate remedy.

Ratio Decidendi: Writ interference with an appealable assessment order is unwarranted in the absence of exceptional circumstances, and issues involving disputed facts or statutory amendment claims should ordinarily be pursued before the appellate authority.

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