Civil challenge to municipal tax assessment barred where statute provides complete remedy and no irreparable injury is shown.

A taxing statute that provides a complete machinery for assessment, appeal, and finality bars civil-court challenges to valuation, assessment, and liability except in the manner it prescribes. On that basis, the civil suit could not assail the levy of house tax, water tax, or sewerage tax, and the Jal Sansthan could rely on the municipal assessment where it had made no separate annual-value assessment. Interim injunction to stop recovery of quantified tax demands was also unavailable because no irreparable injury was shown. The refusal of interim relief was therefore sustained.

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Issues: (i) Whether the civil suit could question the assessment and levy of house tax, water tax, and sewerage tax, and whether the Jal Sansthan could proceed on the basis of the Nagar Nigam assessment where no independent assessment had been made; (ii) Whether the plaintiff was entitled to interim injunction restraining recovery of the tax demands.

Issue (i): Whether the civil suit could question the assessment and levy of house tax, water tax, and sewerage tax, and whether the Jal Sansthan could proceed on the basis of the Nagar Nigam assessment where no independent assessment had been made.

Analysis: The statutory scheme for municipal taxation provided a complete machinery for assessment, appeal, and finality. The provision barring civil-court interference in matters of taxation excluded a challenge to valuation, assessment, and liability except in the manner provided by the statute. The water and sewerage law further permitted the Jal Sansthan to assess annual value, but until it did so, the annual value assessed by the local body for house tax became the basis for levy under that Act. As no independent assessment by the Jal Sansthan had been made, it could rely on the municipal assessment. In the circumstances, the tax demands could not be assailed by a civil suit.

Conclusion: The challenge to the tax assessment and levy in the civil suit was barred, and the Jal Sansthan was entitled to proceed on the municipal assessment basis.

Issue (ii): Whether the plaintiff was entitled to interim injunction restraining recovery of the tax demands.

Analysis: Interim injunction requires a showing of irreparable injury. The demands in question were quantified monetary liabilities recoverable as tax, and refusal of restraint would not cause injury incapable of compensation in money. On the facts, no ground existed for grant of interim protection.

Conclusion: The plaintiff was not entitled to interim injunction.

Final Conclusion: The order refusing interim relief was upheld and the appeal failed.

Ratio Decidendi: Where a taxing statute creates a complete assessment and appeal mechanism and expressly bars challenges outside that scheme, civil-court jurisdiction is excluded; interim injunction will not lie to restrain recovery of a quantified tax demand absent irreparable injury.

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