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Issues: Whether the writ petition challenging rejection of refund and the appellate order was maintainable in view of the statutory appeal remedy, and whether the orders suffered from violation of natural justice for want of effective personal hearing.
Analysis: The dispute arose from refund proceedings under the GST framework in which the petitioner had submitted replies to the show cause notices and had been given opportunities of personal hearing at the adjudication stage and again at the appellate stage. The Court distinguished between inherent lack of jurisdiction and an alleged erroneous exercise of jurisdiction, holding that writ interference is ordinarily reserved for exceptional cases involving jurisdictional infirmity. On the facts, the record showed that the petitioner had notice, had participated in the proceedings, and had availed hearings, so the grievance was essentially one of non-acceptance of submissions rather than total denial of hearing. The Court also held that the statutory appeal before the GST Appellate Tribunal was a functional and efficacious remedy, and that questions concerning refund entitlement and adequacy of supporting material were matters for that forum.
Conclusion: The Court declined to interfere under Article 226 and relegated the petitioner to the statutory appellate remedy.
Ratio Decidendi: Where a statutory appellate remedy is available and the record shows that the party was put to notice and afforded opportunity to reply and be heard, writ jurisdiction is not invoked merely because the party disputes the correctness of the findings or the appreciation of material.