Alternate remedy rule bars writ challenge to reassessment notice and completed assessment where statutory appeal is available.

A writ challenge to notice under section 148 and the consequential assessment was held not maintainable where the assessment had already been completed and an efficacious statutory appellate remedy was available. The petitioner's objection that the conditions for invoking the extended limitation under section 149(1)(b) were not satisfied did not justify writ interference, because no exceptional circumstance was shown to displace the alternate-remedy rule under Article 226. The court therefore declined to exercise writ jurisdiction and left the assessee to pursue the statutory appeal.

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Issues: Whether the writ petition challenging the notice under section 148 and the consequential assessment was maintainable in view of the availability of an efficacious statutory appeal.

Analysis: The petitioner assailed the reopening on the ground that the threshold for invoking the extended limitation under section 149(1)(b) was not met. The Court held that the assessment had already been completed and that the challenge to the assessment order ought to be pursued through the statutory appellate remedy. It found that no exceptional circumstance was made out to justify exercise of writ jurisdiction under Article 226, and that the existence of an alternate efficacious remedy barred interference.

Conclusion: The writ petition was not entertainable and was dismissed, leaving the petitioner to avail the appellate remedy.

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