Civil suit barred against excise assessment where statutory finality and appeal remedies governed challenge to demand validity.

Where a taxing statute gives finality to assessment orders and provides appellate and revisional remedies, a civil suit will not lie merely to challenge the correctness of the assessment or the demand quantified under it. Here, the assessment had already passed through the statutory hierarchy, and the suit did not allege lack of competence, ultra vires levy, or collection beyond statutory authority. Civil court jurisdiction was therefore barred, and the challenge had to be pursued only through the statutory remedies.

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Issues: Whether a civil suit was maintainable to challenge the central excise assessment and demand, or whether the statutory finality under the excise enactment barred civil court jurisdiction.

Analysis: The assessment had been carried through the statutory hierarchy of appeal and revision. The challenge in the suit was not to the competence of the taxing authority or the constitutional validity of the levy, but only to the correctness of the assessment and the quantum demanded. In such circumstances, the finality clause in the excise law excluded a civil suit, because questions relating to the correctness or validity of an assessment are to be pursued only through the remedies provided by the statute.

Conclusion: The civil suit was not maintainable, and the objection to civil court jurisdiction was upheld.

Ratio Decidendi: Where a taxing statute gives finality to assessment orders and provides an adequate appellate and revisional machinery, a civil suit does not lie to challenge only the correctness of the assessment; civil court jurisdiction remains open only where lack of jurisdiction, ultra vires action, or illegal collection beyond statutory authority is specifically established.

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