Chhattisgarh HC says Writ Cannot Bypass a Pending Statutory Appeal

Disha Education Society challenged a Section 148 notice alleging that the reassessment was time-barred and based on a change of opinion. During the writ proceedings, however, a reassessment order was passed and the assessee filed a statutory appeal against it. The High Court held that, having already invoked the appellate remedy and not challenged the reassessment order in the writ petition, the assessee could not maintain parallel proceedings under Article 226.