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of The HC dismissed the writ petition challenging an assessment order on grounds of limitation and absence of Document Identification Number (DIN). The Court held that questions of limitation involve mixed questions of fact and law that cannot be summarily determined on affidavits alone. Regarding the DIN issue, the Court noted that the Supreme Court had stayed a similar Calcutta HC decision in Tata Medical Center Trust. Following Bank of Baroda v. Farooq Ali Khan, the Court emphasized that statutory tribunals are constituted to determine questions of law and fact, and High Courts should not substitute themselves as decision-making authorities when exercising judicial review powers. The petition was deemed not maintainable as alternative and efficacious statutory remedies remained available to the petitioner.
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