Alternative statutory remedy bars writ interference in fiscal assessment disputes absent a clear natural justice violation.

An efficacious statutory appeal ordinarily bars writ interference in fiscal matters, and bypass is justified only on recognised exceptional grounds such as breach of natural justice, excess of jurisdiction, violation of fundamental rights, or a vires challenge. Here, the show cause notice was detailed, repeated summons and opportunities were granted, and no substantive denial of hearing was established. No exceptional circumstance was made out to override the alternate remedy. The writ petitions were therefore not maintainable, and the petitioner was left to pursue the statutory appeal under the Rajasthan Goods and Services Tax Act, 2017.

---

---

Issues: Whether the writ petitions challenging the assessment orders under the Rajasthan Goods and Services Tax Act, 2017 were maintainable in view of the alternative statutory remedy of appeal, and whether any exception based on violation of natural justice was made out.

Analysis: The availability of an efficacious statutory appeal under Section 107 ordinarily bars writ interference in fiscal matters. Interference is justified only in exceptional cases such as breach of fundamental rights, violation of natural justice, excess of jurisdiction, or challenge to vires. On the facts, the show cause notice was found to be detailed, the petitioner had been issued repeated summons and granted opportunities, including adjournments, and no substantive denial of hearing was established. The Court therefore held that no case of violation of natural justice or other exceptional circumstance was made out to bypass the statutory appellate remedy.

Conclusion: The writ petitions were not maintainable and the petitioner was required to pursue the statutory appeal remedy.

Final Conclusion: The challenge to the assessment orders was rejected at the threshold, leaving the petitioner to avail the alternative appellate remedy under the Act.

Ratio Decidendi: In a fiscal dispute, a writ petition will not be entertained against an assessment order where an efficacious statutory appeal is available, unless a recognized exceptional ground for bypassing the alternate remedy is clearly established.

---