Writ jurisdiction limits bar fact-heavy GST assessment challenges where statutory appeal remains the proper remedy.

A writ challenge to an assessment order under the CGST Act and a rectification order was held not maintainable where the dispute turned on contested factual questions about alleged excess input tax credit. The court noted that the orders were passed after notice and hearing, and that such fact-intensive issues are not ordinarily examined in writ jurisdiction under Article 226. The proper remedy was the statutory appellate mechanism, and the challenge was left to be pursued in appeal.

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Issues: Whether the writ petition challenging the assessment order under Section 73(9) of the Central Goods and Services Tax Act, 2017 and the rectification order was maintainable in view of disputed questions of fact and the availability of the statutory appellate remedy.

Analysis: The assessment and rectification orders were passed after notice and hearing. The challenge required adjudication of disputed factual questions relating to alleged excess input tax credit, which are not ordinarily examined in writ jurisdiction under Article 226 of the Constitution of India. The proper course was to pursue the statutory appellate remedy.

Conclusion: The writ petition was not entertainable on merits in exercise of writ jurisdiction, and the challenge to the orders was left to the statutory appeal mechanism.

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