Writ jurisdiction in tax reassessment matters is usually declined where disputed facts can be resolved under the statutory remedy scheme.

In tax reassessment disputes, the High Court will ordinarily decline to exercise writ jurisdiction under article 226 where the challenge turns on disputed facts and the Income-tax Act provides an adequate statutory remedy. Questions such as limitation, service of notice, and whether the estate was properly represented are matters for the income-tax authorities to determine under the departmental machinery. Absent a clear jurisdictional defect or manifest illegality on the face of the record, the writ petition should not bypass the statutory hierarchy, and the parties must pursue the available remedies before the tax authorities.

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Issues: Whether the writ petition challenging reassessment notices should be entertained under article 226 of the Constitution of India despite the availability of remedies under the Income-tax Act, and whether the High Court should examine the disputed questions relating to limitation, service of notice, and representation of the estate at this stage.

Analysis: The petition raised questions that depended on disputed facts, including whether one legal heir effectively represented the estate, whether the notices were properly served, and whether the notices were barred by time. The Court held that such questions were pre-eminently for the income-tax authorities to determine under the statutory machinery. It found no patent jurisdictional infirmity or grave illegality on the face of the record that would justify bypassing the departmental hierarchy. The Court also declined to enter into the merits of the controversy or to express any view that might prejudice the authorities' independent consideration.

Conclusion: The writ petition was not maintainable at this stage and the petitioners were left to pursue the statutory remedies before the income-tax authorities.

Final Conclusion: The Court refused to exercise its extraordinary writ jurisdiction and directed the parties to proceed under the income-tax adjudicatory scheme, resulting in dismissal of the petition.

Ratio Decidendi: In tax matters, where the challenged action turns on disputed facts and the statute provides an adequate machinery for adjudication and relief, the High Court will ordinarily decline to exercise writ jurisdiction unless there is a clear jurisdictional defect or manifest illegality warranting immediate interference.

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