Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The court addressed whether extraordinary writ relief was maintainable where an alternate statutory remedy with a pre-deposit exists and whether the impugned order was time-barred or tainted by denial of natural justice; factual mixed-questions (service, exemption status, limitation) required adjudication and did not justify bypassing the statutory remedy. The statutory pre-deposit requirement was held not to render the remedy inefficacious. Consequently the writ was declined; petitioner directed to file the prescribed statutory appeal within six weeks after complying with pre-conditions including pre-deposit, and the appellate authority must decide the appeal on merits without disputing limitation. - HC
The court addressed whether extraordinary writ relief was maintainable where an alternate statutory remedy with a pre-deposit exists and whether the impugned order was time-barred or tainted by denial of natural justice; factual mixed-questions (service, exemption status, limitation) required adjudication and did not justify bypassing the statutory remedy. The statutory pre-deposit requirement was held not to render the remedy inefficacious. Consequently the writ was declined; petitioner directed to file the prescribed statutory appeal within six weeks after complying with pre-conditions including pre-deposit, and the appellate authority must decide the appeal on merits without disputing limitation. - HC
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