Writ interference and limitation under VAT law declined where factual disputes required appellate scrutiny and appeal remedy was available.

Writ interference was found unwarranted where the challenge involved limitation and fact-dependent merits under the Andhra Pradesh Value Added Tax Act, 2005. The limitation objection was rejected by applying the statutory period under Section 37 and the Supreme Court's Covid-19 exclusion order for computation of time. On the merits, issues concerning warranty replacement, exemption, and documentary verification required appreciation of records by the appellate authority, not writ adjudication. As a statutory appeal was available, the assessee was relegated to that remedy and the writ court declined to examine the factual merits.

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Issues: Whether interference was warranted in writ jurisdiction against the assessment order on the grounds of limitation and merits, and whether the petitioner should be relegated to the statutory appeal remedy.

Analysis: The challenge to limitation was repelled by treating the proceeding as one governed by the statutory period under Section 37 of the Andhra Pradesh Value Added Tax Act, 2005, along with the Supreme Court order excluding the relevant Covid-19 period for computation of limitation. On the merits, the dispute turned on verification of records and documentary evidence relating to warranty replacement and alleged exemption, which required examination by the appellate authority rather than writ adjudication. The Court also noted that a statutory appeal was available.

Conclusion: Interference was declined and the petitioner was relegated to the statutory appellate remedy.

Final Conclusion: The writ court did not adjudicate the factual merits and left the assessee to pursue the prescribed appeal.

Ratio Decidendi: Where the dispute depends on appreciation of evidence and a statutory appellate remedy is available, writ interference is unwarranted, particularly when limitation is saved by the applicable exclusion order.

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