Statutory appellate remedy governs assessment challenges where the show-cause notice alleges transactions with bogus taxpayers.

A show-cause notice alleging inward supplies from bogus taxpayers provides a basis to reject a jurisdictional challenge to an assessment order based on the asserted absence of allegations of fraud, wilful misstatement or suppression of facts. Where the statutory framework provides an appellate remedy against the assessment order, the challenge should be pursued through that mechanism rather than by writ intervention. The jurisdictional objection was therefore not accepted, and the assessee was required to file a statutory appeal.

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Issues: Whether the challenge to the assessment order on the ground that it lacked allegations of fraud, wilful misstatement or suppression of facts warranted writ interference despite the statutory appellate remedy.

Analysis: The show-cause notice alleged receipt of inward supplies of goods and services from bogus taxpayers. This provided a basis to reject the asserted absence of jurisdiction. An appeal against the assessment order was available under the statutory appellate mechanism.

Conclusion: The jurisdictional challenge was not accepted; the assessee was required to pursue the statutory appeal.

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