- (1.) Heard the learned counsel on both sides. Leave granted.
(2.) A writ petition was filed by the appellant assessee (Bharat Petroleum Corporation Limited) under Rule 21(1) and Rule 21(2) of the Punjab Value Added Tax Rules , 2005.
(3.) The case of the appellant was that the order of assessment disallowing input tax credit on the purchase value of the product was illegal. This assessment order was challenged by the appellant before the High Court by way of writ petition without exhausting the statutory remedy of appeal under the Punjab Value Added Tax Act, 2005. In the circumstances, vide impugned judgment, the High Court has dismissed the writ petitions directing the appellant herein to exhaust the statutory remedy. However, after directing the assessee to exhaust the statutory remedy, the High Court has made observations on the merits of the case. Hence, this civil appeal.;