Statutory appellate remedy must be exhausted before invoking writ jurisdiction against VAT assessment orders.

Writ jurisdiction under Article 226 is not the normal route where the Tamil Nadu Value Added Tax Act, 2006 provides a complete appellate hierarchy. Allegations of wrong application of the amended input tax credit provision, jurisdictional error, or similar legal grounds can be examined by the statutory appellate authorities, which are competent to review the original record and decide facts and law. Routine bypass of that remedy is therefore barred, and writ relief is confined to exceptional cases such as gross injustice or violation of fundamental rights. The petitions were required to proceed through the statutory appeal mechanism first.

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Issues: Whether writ petitions challenging assessment orders under the Tamil Nadu Value Added Tax Act, 2006 were maintainable without first exhausting the statutory appellate remedy, and whether alleged erroneous application of the amended input tax credit provision justified bypassing that remedy.

Analysis: The statutory scheme under the Tamil Nadu Value Added Tax Act, 2006 provides a layered appellate structure, including appeal to the Appellate Deputy Commissioner, the Appellate Tribunal, and further remedies under the Act. Exhaustion of the statutory appeal remedy is the rule, and invoking writ jurisdiction under Article 226 of the Constitution of India is only an exception in exceptional cases such as gross injustice, violation of fundamental rights, or other narrowly recognised situations. The Court held that questions relating to alleged wrong application of the amended provision, jurisdictional error, and other legal grounds can be examined by the appellate authorities, which are competent to consider the original record and render findings on facts and law. The availability of an appellate forum therefore barred routine recourse to writ jurisdiction.

Conclusion: The writ petitions were not maintainable in the first instance and the petitioners were required to pursue the statutory appellate remedy.

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