Alternative statutory appeal bars writ challenge where draft assessment objections were not filed before the Dispute Resolution Panel.

Failure to file objections to a draft assessment order before both the Dispute Resolution Panel and the Assessing Officer permits completion of assessment on the draft order under the statutory scheme. Where an appeal against that assessment is available under the tax statute, the alternative remedy is treated as efficacious and writ jurisdiction under Article 226 is not warranted. The stated position is that the writ petition is not entertainable, while the taxpayer may pursue the statutory appeal and raise all merits there.

---

---

Issues: Whether the writ petition challenging the assessment order was entertainable despite the statutory appellate remedy, where objections to the draft assessment order were not filed before the Dispute Resolution Panel.

Analysis: Section 144C(2)(b) requires objections to a draft assessment order to be filed before both the Dispute Resolution Panel and the Assessing Officer. As no objections were filed before the Panel, Section 144C(3) permitted completion of the assessment on the basis of the draft order. The statutory scheme also provided an appeal under Section 246A. In view of the efficacious alternative remedy under the taxing statute, exercise of jurisdiction under Article 226 was not warranted.

Conclusion: The writ petition was not entertainable; the petitioner must pursue the statutory appellate remedy, with all merits left open.

---