Alternative statutory remedy bars challenge to revisional order after reassessment is completed and appeal lies against the reassessment order.

Where reassessment directed under a revisional order had already been completed and the assessee had participated in those proceedings, the challenge to the revisional order was not entertained on merits because a statutory appeal lay against the reassessment order. The court treated the available appellate remedy as the proper course and declined to examine the revisional challenge, as no useful purpose would be served by doing so after completion of reassessment. The dispute was therefore disposed of without adjudication of the substantive tax issues, leaving the assessee to pursue the alternative statutory appeal remedy.

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Issues: Whether the appeal against the revisional order should be entertained when the reassessment directed by that order had already been completed and a statutory appeal remedy was available against the reassessment order.

Analysis: The reassessment proceedings were completed pursuant to the revisional order, and the assessee had participated in those proceedings. In that situation, no useful purpose would be served by examining the challenge to the revisional order in the present appeal. The proper course was to pursue the statutory appellate remedy against the reassessment order, in keeping with the principle that where a remedy of appeal is provided, it must ordinarily be exhausted.

Conclusion: The appeal was not entertained on the merits and the assessee was left to pursue the statutory appeal remedy against the reassessment order.

Final Conclusion: The dispute was disposed of without adjudication on the substantive tax issues, leaving the assessee to avail the alternative statutory appellate remedy.

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