Statutory appeal remedy bars writ review of appealable assessment orders where prior attachment relief was limited to procedural opportunity.

Writ jurisdiction was declined against assessment orders because an efficacious statutory appeal was available. The Court noted that the earlier orders setting aside distraint attachment were limited to the absence of opportunity before attachment and did not absolve the assessee from tax liability or prevent the revenue from proceeding with assessment after fresh notice. As the impugned orders were appealable, the Court refused to examine the merits in writ proceedings and left the petitioner to pursue the appellate remedy.

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Issues: Whether the writ petitions challenging the assessment orders were liable to be entertained when the impugned orders were appealable and the petitioners were given liberty to pursue the statutory remedy.

Analysis: The assessment orders were passed after issuance of a fresh notice pursuant to the earlier directions, and the Court found that the prior orders setting aside the distraint attachment were confined to the absence of opportunity before attachment. Those earlier directions did not exonerate the assessee from tax liability or prevent the authorities from proceeding on the assessment side. The impugned assessment orders were held to be appealable, and the Court declined to examine the merits in writ jurisdiction in view of the available appellate remedy.

Conclusion: The writ petitions were not entertained on merits, and the petitioner was left to work out the statutory appeal remedy.

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