Classification disputes under TNVAT should be pursued through statutory appeal, not writ jurisdiction, when factual examination is required.

Classification disputes under the TNVAT regime are ordinarily left to the statutory appellate hierarchy where effective remedies are available. Because the assessment depended on factual examination of the goods and the assessment record, and the impugned order had already considered earlier advance ruling orders, the High Court held that writ interference under Article 226 was not warranted. The petitioner was directed to pursue the appeal before the Appellate Commissioner and, if necessary, the Tribunal, with the classification issues left open for consideration in that forum.

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Issues: Whether the writ petition challenging the assessment order should be entertained in view of the availability of the statutory appellate remedy, when the dispute concerns classification of goods under the TNVAT regime.

Analysis: The dispute turned on classification of the goods assessed under the TNVAT Act, a matter requiring factual examination and appreciation of the assessment record. The impugned assessment order had been passed after consideration of the earlier advance ruling orders and the Court noted that such issues are best addressed within the statutory hierarchy under the TNVAT Act. The availability of an appeal to the Appellate Commissioner, and thereafter to the Tribunal, weighed against interference in writ jurisdiction under Article 226 of the Constitution of India. The Court also left the classification questions open to be urged before the appellate authority.

Conclusion: The writ petition was not entertained and the petitioner was relegated to the statutory appellate remedy.

Ratio Decidendi: Where an assessment dispute turns on classification of goods and an effective statutory appeal is available, writ interference under Article 226 is ordinarily not warranted.

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