Writ jurisdiction limited where disputed facts and alternative statutory appeal exist; petition against rectification orders dismissed.

Where a petition challenges rectification orders under the remedy for errors apparent on the record, the court emphasised that writ jurisdiction is circumscribed when contested factual issues arise, the underlying assessment was not attacked by the statutory appellate process, rectification applications were considered after issuance of notices and a personal hearing, and an alternative statutory appeal is available; accordingly the writ petition was held not maintainable and dismissed, with the petitioner left to pursue the prescribed statutory remedies.

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Issues: Whether a writ petition under Article 226 challenging rectification orders issued under Section 161 can be entertained where disputed questions of fact arise, the assessment order was not challenged, rectification applications were considered after personal hearing, and an alternative remedy of appeal is available.

Analysis: Relevant legal framework includes the remedial scope of Section 161 (rectification of errors apparent on the face of the record), the statutory scheme for assessment and appeal under the Central Goods and Services Tax regime, and the limits on exercise of extraordinary writ jurisdiction where disputed factual issues and alternative statutory remedies exist. The authorities issued pre-intimation and show cause notices, passed an assessment under Section 74 of the Central Goods and Services Tax Act, 2017, and later considered rectification applications filed under Section 161 after providing notice for and conducting a personal hearing. The petitioner did not file objections to the notices nor challenge the original assessment order by the statutory appellate process. The matter before the Court involves contested factual determinations relating to alleged suppression of outward supplies and tax liability, which are suitable for adjudication through the prescribed statutory remedy of appeal rather than by exercise of writ jurisdiction.

Conclusion: The writ petition is not maintainable and is dismissed; the petitioner is left free to pursue the statutory remedies available under law.

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