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Issues: Whether the writ petition challenging the assessment order should be entertained without first exhausting the statutory appellate remedy.
Analysis: The writ court reiterated that appellate remedy is the normal rule and that bypassing it is an exception reserved for cases showing imminent threat, gross injustice, or similarly compelling grounds. It emphasized that disputed questions involving facts and law, which depend on records and evidence, are to be examined by the appellate authority, which functions as the final fact-finding forum. The scope of judicial review under Article 226 is confined to examining the decision-making process and not reappreciating the merits of the assessment itself.
Conclusion: The writ petition was not entertained on merits and the petitioner was relegated to the statutory appeal remedy.
Final Conclusion: The assessment challenge was left to be pursued before the appellate forum, and the High Court declined to exercise writ jurisdiction at this stage.
Ratio Decidendi: Where an effective statutory appellate remedy exists, writ jurisdiction should ordinarily not be invoked to adjudicate disputed facts or to bypass the appellate forum's role as the final fact-finding authority.