High Court Correctly Refused Writ Petition Against Assessment Order Involving Factual Determination When Statutory Appeal Existed

High Court Correctly Refused Writ Petition Against Assessment Order Involving Factual Determination When Statutory Appeal Existed

• The assessee filed a writ petition under Article 226 of the Constitution of India challenging the assessment order passed under Section 143(3).
• The assessee contended that the Assessing Officer made additions regarding transactions that did not pertain to the relevant assessment year.
• The High Court dismissed the writ petition, holding that the assessee’s grievance required appreciation of facts and arguments that should properly be advanced before the Appellate Authority [CIT(A)].
• The High Court concluded that this was not a fit case to exercise its extraordinary writ jurisdiction under Article 226 when statutory remedies were available.
• Aggrieved by the High Court’s order, the assessee filed a Special Leave Petition (SLP) before the Supreme Court.

• Held, yes. The Supreme Court found no good ground or reason to interfere with the impugned order of the High Court.
• Held, yes. Consequently, the Special Leave Petition (SLP) filed by the assessee was dismissed in favor of the Revenue.

• Exhaustion of Alternative Statutory Remedies: High Courts will generally not entertain writ petitions under Article 226 against assessment orders where statutory appeal mechanisms (such as appealing to CIT(A) under Section 246A) exist.
• Factual Disputes Require Appellate Forum: Questions involving the appreciation of facts—such as establishing whether specific transactions pertain to a particular assessment year—must be agitated before appellate authorities rather than through writ proceedings.
• Supreme Court Deference: The Apex Court will not interfere with High Court orders refusing writ jurisdiction when the assessee bypasses statutory appellate remedies for factual disputes.