Writ jurisdiction and tax assessments: Article 226 is generally unavailable where the statute provides a complete appellate remedy.

Writ petitions under Article 226 are ordinarily not maintainable against assessment orders where the taxing statute provides a complete remedial hierarchy of appeal, further appeal and reference on questions of law. The existence of that self-contained statutory machinery requires the assessee to pursue the remedies created by the Act, especially where the challenge concerns the regularity of proceedings or the correctness of a best judgment assessment rather than inherent lack of jurisdiction. Alleged procedural irregularity or denial of natural justice will not justify direct writ intervention where notice was issued and opportunities were afforded. Direct recourse to writ jurisdiction is therefore restricted to cases of clear jurisdictional defect or patent breach of natural justice.

---

---

Issues: Whether writ petitions under Article 226 were maintainable against assessment orders when the statute provided an appeal, second appeal, and reference mechanism, and whether the assessments could be treated as nullities on the ground of alleged procedural irregularity or denial of natural justice.

Analysis: The assessment authority had jurisdiction to make the assessments under the sales tax enactments, and the objections raised went to the regularity of the proceedings and the correctness of the best judgment assessment rather than to any inherent lack of jurisdiction. The statutory scheme provided a complete machinery for redress, including appeal, further appeal, and reference on questions of law, and the existence of that machinery required the assessee to pursue the remedy created by the Act. The materials also showed that notice had been issued and opportunities had been afforded, so the refusal of a further adjournment did not amount to a violation of natural justice warranting direct writ intervention.

Conclusion: The writ petitions were not maintainable, and the challenge had to be pursued through the statutory appellate process.

Final Conclusion: Direct recourse to writ jurisdiction was declined because the statute furnished an adequate and efficacious remedial hierarchy for challenging the assessments.

Ratio Decidendi: Where a taxing statute creates a complete self-contained remedy for challenging an assessment, the extraordinary writ jurisdiction will not ordinarily be invoked to question matters that can be effectively agitated in the prescribed statutory appeals, absent a clear case of inherent lack of jurisdiction or patent breach of natural justice.

---