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Issues: Whether the writ petition challenging the assessment and penalty-related orders was maintainable in the presence of disputed questions of fact and an efficacious statutory appeal remedy.
Analysis: The order recorded that the assessment materials had been considered and that the grievance did not establish a violation of natural justice. Since the controversy involved disputed questions of fact, the Court declined to adjudicate the merits in writ jurisdiction and left the petitioner to pursue the statutory appeal remedy.
Conclusion: The writ petition was not entertained on merits and the petitioner was relegated to the statutory appellate remedy.