Writ jurisdiction and disputed tax facts: assessment order left intact, with the party directed to statutory appeal.

Writ interference under Article 226 was declined where the tax demand depended on disputed facts and supporting documents, making the matter unsuitable for factual reappraisal in writ proceedings. The court noted that a statutory appellate remedy remained available and that the petitioner was still within the condonable period for appeal, so the assessment order was left undisturbed and the petitioner was relegated to the appeal mechanism.

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Issues: Whether the assessment order warranted interference in writ jurisdiction when the dispute turned on factual questions and a statutory appeal remedy was available.

Analysis: The challenge concerned tax demand on the price difference component and required examination of disputed facts and supporting documents. The writ court declined to undertake that factual inquiry under Article 226 of the Constitution of India, noting that a statutory appellate remedy remained available and that the petitioner was still within the condonable period for appeal.

Conclusion: The assessment order was not interfered with in writ jurisdiction, and the petitioner was relegated to the statutory appeal remedy.

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