Statutory appellate remedy must be exhausted before writ jurisdiction is invoked for assessment disputes and alleged legal error.

An efficacious statutory appellate hierarchy under the Tamil Nadu Value Added Tax Act, 2006 ordinarily must be exhausted before invoking writ jurisdiction under Article 226. Allegations of jurisdictional error or erroneous application of an amended provision do not, by themselves, justify bypassing the appellate process, which is designed to examine disputed assessment issues first. Writ relief remains discretionary and is reserved for exceptional cases such as gross injustice or violation of natural justice. The assessment challenge was therefore required to be pursued before the statutory appellate authority, with liberty to seek condonation of delay and adjudication on merits.

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Issues: Whether the writ petition could be entertained without exhausting the statutory appellate remedy under the Tamil Nadu Value Added Tax Act, 2006, on the ground of alleged jurisdictional error and erroneous application of the amended provision.

Analysis: The statutory scheme under the Tamil Nadu Value Added Tax Act, 2006 provides a hierarchy of remedies, including appeal to the Appellate Deputy Commissioner, further appeal to the Appellate Tribunal, and subsequent remedies before the High Court. The availability of these remedies reflects the legislative intent that disputed questions of assessment, including alleged errors in application of law and jurisdictional objections, should ordinarily be examined by the appellate forum first. Writ jurisdiction under Article 226 of the Constitution of India is discretionary and is not meant to bypass a complete appellate mechanism except in exceptional circumstances such as gross injustice, violation of natural justice, or other compelling grounds. The Court held that the alleged error in applying the amended provision did not justify bypassing the statutory appellate process.

Conclusion: The writ petition was not maintainable without first pursuing the statutory appeal, and the petitioner was required to avail the appellate remedy.

Final Conclusion: The impugned assessment challenge was left to be pursued before the statutory appellate authority, with liberty to seek condonation of delay and adjudication on merits.

Ratio Decidendi: Where an efficacious statutory appellate remedy exists, writ jurisdiction should not be invoked to bypass the appellate hierarchy merely on allegations of jurisdictional error or erroneous application of law, save in exceptional cases.

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