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Raleigh Investment Co., Ltd. vs Governor-General In Council. on 9 April, 1943

4. The plaint states that the order passed by the Deputy Commissioner is illegal and ultra vires and not sustainable on the merits of the case, as also the orders of the Sales Tax Officers. This cannot be agitated in a civil Court and the decision of the Privy Council in Raleigh Investment Co. Ltd. v. Governor General in Council (1947) 2 M.L.J. 16 : (1947) F.L.J. 45 : 1947 F.C.R. 59(P.C.), furnishes the answer. The Judicial Committee held that an assessment made under the machinery provided by the Act is not a nullity, like an order of Court lacking jurisdiction. Reliance of such a provision is not an excess of jurisdiction, but a mistake of law made in the course of its exercise, and the suit is in truth directed exclusively to set aside or modify "an assessment made under the Act" and hence it is not maintainable. Their Lordships further pointed out that the circumstances that the assessing officer had taken into account an ultra vires provision of the Act is, in this view, immaterial in determining whether the assessment is made under the Act. The phrase describes the provenance of the assessment and does not relate to its accuracy in point of law. The use of the machinery provided by the Act, not the result of that use, is the test. It is apparent that where the form of prayer did not use the very words but the substance is clear that a modification or setting aside the assessment is sought for, the plaintiff-assessee has to seek the remedy provided under Section 11 and 12 to 12-D of the Act, which is a self-contained Act and prescribes a special machinery for the redress of the grievance. Therefore, the declaration sought for in this case cannot be regarded as having any relevancy except as leading up to the claim for repayment. Therefore, the learned advocate for the appellant has not succeeded in taking this case out of the purview of the hierarchy of tribunals constituted for this purpose under the Madras General Sales Tax Act which is a self-contained and comprehensive legislation which enables an assessee to question the assessment imposed on him.
Calcutta High Court Cites 81 - Cited by 220 - Full Document
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