Writ jurisdiction is inappropriate for disputed reassessment facts when an effective statutory appeal remains available.

Writ jurisdiction under Article 226 is not appropriate for reassessment disputes turning on disputed facts, including labour charges in works contracts, purchase tax exposure, processing loss, and TDS claims requiring document verification. Where such issues depend on evidence and the assessee has an efficacious statutory appeal, the writ court should decline interference and leave the matter to the appellate forum. The assessee was therefore rightly relegated to the statutory remedy.

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Issues: Whether the writ court should interfere with reassessment orders involving disputed questions of fact, or relegate the assessee to the statutory appellate remedy.

Analysis: The assessment disputes turned on factual matters such as the extent of labour charges in works contracts, levy of purchase tax on alleged purchases from unregistered dealers, processing loss, and rejection of TDS-related claims for want of statutory forms. Such issues required examination of evidence and verification of documents, which is not suited to writ jurisdiction under Article 226 of the Constitution of India. The existence of an efficacious statutory appeal, coupled with the failure to respond to the revised notices, justified relegation to the appellate forum.

Conclusion: The writ court was not required to interfere, and the assessee was rightly directed to avail the statutory appeal remedy.

Ratio Decidendi: Writ jurisdiction under Article 226 is not to be invoked for adjudication of disputed questions of fact where an efficacious statutory appellate remedy is available.

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