Writ jurisdiction is exceptional where an effective statutory GST appeal exists; factual disputes should go to the appellate authority first.

Writ jurisdiction under Article 226 is exceptional and should not ordinarily be used to challenge assessment orders when an effective statutory appeal is available under section 31 of the Tamil Nadu GST Act. The appellate authority is the proper forum for disputed facts and mixed questions of fact and law, and interference without exhausting the appeal remedy is indicated only for lack of jurisdiction, mala fides, or imminent gross injustice. Mere allegations of breach of natural justice are insufficient to bypass the statutory appellate process. The Appellate Deputy Commissioner was identified as the appropriate appellate authority, and the petitioners were directed to pursue the statutory remedy.

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Issues: Whether the writ petitions challenging assessment orders were maintainable without first availing the statutory appellate remedy under section 31 of the Tamil Nadu Goods and Services Tax Act, 2017.

Analysis: The appellate authority was treated as the proper forum for examining disputed questions of fact and mixed questions of fact and law. The writ jurisdiction under Article 226 of the Constitution of India was held to be exceptional and not ordinarily to be invoked when an effective statutory appeal is available. Interference without exhausting the appellate remedy was indicated only in cases involving lack of jurisdiction, mala fides, or imminent gross injustice. Mere allegations of violation of natural justice were held insufficient to bypass the statutory appeal mechanism. The Court also noted that the Appellate Deputy Commissioner was the appropriate appellate authority for the orders challenged.

Conclusion: The writ petitions were not entertained on merits, and the petitioners were relegated to the statutory appellate remedy.

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