Writ Jurisdiction: not maintainable where an efficacious statutory appeal exists; no exceptional natural justice breach found.

The HC considered whether Article 226 writ relief is maintainable despite an efficacious statutory appeal under the Income tax Act and whether the assessment dated 19.03.2024 breached natural justice. The court applied the principle that writ jurisdiction is an extraordinary, discretionary remedy and where a self contained, adequate and efficacious appellate scheme exists the writ should not substitute that remedy; outcome: writ petition rejected as not maintainable. On natural justice the court found contested issues to be fact intensive, no demonstrated total disregard of procedure or exceptional breach; outcome: no interference on natural justice grounds.

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Issues: (i) Whether a writ petition under Article 226 is maintainable when an efficacious alternative remedy of appeal exists under the Income-tax Act, 1961; (ii) Whether the assessment order dated 19.03.2024 suffered such violation of principles of natural justice as to warrant exercise of writ jurisdiction.

Issue (i): Whether a writ petition under Article 226 is maintainable when an efficacious alternative remedy of appeal exists under the Income-tax Act, 1961.

Analysis: The Income-tax Act, 1961 provides a statutory appellate mechanism including an appeal under Section 250. The assessment was passed under Section 143(3) read with Section 144B. The matters in dispute relate to factual questions concerning production of invoices and the character of the transactions. Established precedent recognises that writ jurisdiction is a discretionary, extraordinary remedy and ordinarily ought not to be invoked where an adequate and efficacious alternative statutory remedy exists, absent exceptional circumstances.

Conclusion: The writ petition is not maintainable in the presence of an efficacious alternative remedy under the Income-tax Act, 1961.

Issue (ii): Whether the assessment order dated 19.03.2024 suffered such violation of principles of natural justice as to warrant exercise of writ jurisdiction.

Analysis: The assessing authority recorded that opportunity was afforded to produce invoices and that the appellant failed to do so; the respondents asserted the transactions concerned a proprietary concern (HUF) and involved disputed facts. The dispute is fact-intensive and there was no finding of total disregard of statutory procedure or a demonstrated exceptional breach of natural justice in the material on record.

Conclusion: There are no exceptional circumstances or proven violation of principles of natural justice that would justify interference by writ jurisdiction in this matter.

Final Conclusion: The appropriate statutory remedy under the Income-tax Act, 1961 is available and effective; disputed factual questions and the absence of exceptional circumstances preclude exercise of writ jurisdiction under Article 226.

Ratio Decidendi: Where a self-contained statutory scheme provides an adequate and efficacious remedy for challenging an assessment, and no exceptional circumstances or demonstrable violation of principles of natural justice exist, writ jurisdiction under Article 226 should not be exercised in lieu of the statutory appellate remedy.

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