High Court in exercise of its writ jurisdiction cannot entertain a challenge to the assessment order when the statutory remedy of appeal stands foreclosed by time limitation: Apex Court

Factual Background: The assessment order dated 21.6.2017 was challenged by the respondent by way of statutory appeal before the Appellate Deputy Commissioner only on 24.9.2018. However, the same had become time barred in view of the provisions of Section 31 of the Andhra Pradesh Value Added Tax Act, 2005. Section 31 states that the statutory appeal is required to be filed within 30 days from the date on which the order or proceeding was served on the assessee. If the appeal is filed after expiry of prescribed period, the delay cannot be condoned beyond the aggregate period of 60 days [...]