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    <description>Alternative statutory remedy does not preclude Article 226 review where an assessment is made without considering relevant facts and law. Payments received by a postgraduate medical student were treated as salary solely on university information, without addressing certificate and governmental material supporting their character as an exempt stipend. Because the stipend-versus-salary characterisation was a vital factual issue, an effective opportunity to submit supporting documents before the Assessing Officer was required. Relegation to the statutory remedy was therefore unsustainable, requiring fresh determination after consideration of the relevant material.</description>
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      <description>Alternative statutory remedy does not preclude Article 226 review where an assessment is made without considering relevant facts and law. Payments received by a postgraduate medical student were treated as salary solely on university information, without addressing certificate and governmental material supporting their character as an exempt stipend. Because the stipend-versus-salary characterisation was a vital factual issue, an effective opportunity to submit supporting documents before the Assessing Officer was required. Relegation to the statutory remedy was therefore unsustainable, requiring fresh determination after consideration of the relevant material.</description>
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