Writ jurisdiction is unavailable for resolving complex factual disputes where statutory alternative remedies exist.

The appellant purchased a Rolls Royce Phantom for personal use at a consideration of Rs. 1.45 Crores

In 2017, the vehicle and its original documents were handed over to one Karthikeyan based on a representation that a third party intended to purchase it for Rs. 80 Lakhs; however, no payment was made

Following a police complaint, the appellant discovered the vehicle had been seized by Income Tax authorities in Kochi

Assessment proceedings were initiated under Section 153C of the Income-tax Act, 1961, resulting in an assessment order dated 29.12.2021

The appellant’s subsequent appeal was rejected by the Commissioner of Income Tax (Appeals) on 07.03.2024

The appellant challenged this via a writ petition, which a learned Single Judge dismissed on 27.01.2026, citing the existence of disputed questions of fact and an alternative statutory remedy

The present writ appeal assails that dismissal.

1. Whether the High Court should entertain a writ petition under Article 226 of the Constitution when the matter involves complex disputed questions of fact requiring evidence for determination

2. Whether the existence of an efficacious alternative statutory remedy under the Income-tax Act, 1961, precludes the exercise of writ jurisdiction

The Court applied the principle that the High Court's jurisdiction under Article 226 is discretionary and will generally not be exercised to bypass a special statutory remedy unless the State's action is arbitrary, unreasonable, or violates Article 14

It relied on Titaghur Paper Mills Co. Ltd. v. State of Orissa (1983), which established that where a statute creates a right or liability and provides a special remedy, that remedy must be exclusively availed

This was bolstered by CCT v. Glaxo Smith Kline Consumer Health Care Ltd (2020) and Mafatlal Industries Ltd. v. Union of India (1997), affirming that Constitutional Courts must exercise jurisdiction consistent with legislative intent and the machinery prescribed by the statute

The Court reasoned that the primary dispute—whether the appellant received payment for the vehicle from Karthikeyan—is a complex factual question that cannot be adjudicated without a thorough consideration of evidence

It noted that writ jurisdiction is not intended for dissecting such factual disputes.

Furthermore, the Court observed that the Income-tax Act, 1961, provides a "complete machinery" for challenging assessments, including appeals to the Tribunal and the High Court on questions of law

By applying the cited precedents, the Bench concluded that the learned Single Judge correctly declined to exercise writ jurisdiction because the appellant had an available and efficacious statutory remedy through the Appellate Tribunal

The Court held that the statutory machinery under the Income-tax Act must be exhausted before seeking constitutional remedies.

However, the Court granted the appellant liberty to file a statutory appeal before the Appellate Tribunal within 30 days from the receipt of the order

The department was previously directed to auction the car and deposit the proceeds into an escrow account pending the final outcome of the proposed appeal

No costs were awarded