Writ jurisdiction and scrutiny selection challenges failed where appellate remedy existed and no procedural unfairness was shown.

Writ jurisdiction under Article 226 was treated as unavailable where a statutory appellate remedy under the Income-tax Act existed, absent exceptional grounds to bypass that mechanism. The scrutiny selection challenge failed because CBDT guidelines on compulsory scrutiny did not bar other lawful selections and did not invalidate random selection by the Assessing Officer. The natural justice objection also failed because the taxpayer did not request a personal hearing in the prescribed manner, and the reply was considered in the assessment order. The assessment orders were therefore upheld.

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Issues: (i) Whether the writ petition was maintainable in view of the statutory appellate remedy under the Income-tax Act, 1961; (ii) Whether the assessment orders were vitiated because the scrutiny selection allegedly did not conform to the CBDT guidelines; (iii) Whether the assessment orders were liable to be interfered with for alleged violation of natural justice on the ground that no personal hearing was granted.

Issue (i): Whether the writ petition was maintainable in view of the statutory appellate remedy under the Income-tax Act, 1961.

Analysis: The petitioner challenged the assessment orders directly under Article 226 despite the availability of an appellate remedy. The extraordinary jurisdiction was invoked only if a compelling ground existed to bypass the statutory mechanism.

Conclusion: The writ petition was not entertained on this ground and the challenge was declined.

Issue (ii): Whether the assessment orders were vitiated because the scrutiny selection allegedly did not conform to the CBDT guidelines.

Analysis: The guidelines relied upon were for compulsory selection of cases for complete scrutiny and did not exclude other cases from being selected for scrutiny. They did not operate as a bar against random selection by the Assessing Officer.

Conclusion: The scrutiny selection was upheld and no illegality was found.

Issue (iii): Whether the assessment orders were liable to be interfered with for alleged violation of natural justice on the ground that no personal hearing was granted.

Analysis: The system provided a specific column for seeking personal hearing, but the petitioner did not mark it as requested. The reply filed was considered in the assessment order, and no personal hearing had been sought in the prescribed manner.

Conclusion: No violation of natural justice was made out.

Final Conclusion: The Court found no ground to invoke writ jurisdiction and upheld the assessment orders.

Ratio Decidendi: Where a statutory appellate remedy exists, writ jurisdiction will ordinarily not be invoked absent exceptional grounds, and administrative scrutiny guidelines do not by themselves preclude lawful selection or invalidate an assessment in the absence of demonstrated procedural unfairness.

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