Finality of Orders-in-Original bars writ challenge to a consequential recovery notice; remedy lies before competent authorities.

A writ challenge to a recovery notice was not maintainable where the underlying Orders-in-Original had already attained finality and were never appealed or otherwise challenged. The recovery notice was treated as a consequential step for realising arrears under the prescribed recovery procedure, not as an independent basis to reopen the concluded liability. Any grievance arising from the recovery process had to be pursued before the competent authorities rather than through writ proceedings against the notice. The challenge therefore failed.

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Issues: Whether the writ petition challenging the recovery notice was maintainable when the underlying Orders-in-Original had attained finality.

Analysis: The recovery notice was issued on the basis of concluded Orders-in-Original passed from 2011 onwards, and those orders were neither appealed nor otherwise challenged. As the foundational orders had become final, the recovery notice was only a consequential step taken to realise arrears in accordance with the prescribed recovery procedure. In such circumstances, the Court held that the grievance, if any, had to be pursued before the competent authorities and not in writ proceedings against the recovery notice.

Conclusion: The writ petition was not entertained and the challenge to the recovery notice failed.

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