RAMSARAN DAS AND BROS. vs COMMERCIAL TAX OFFICER, CALACUTTAAND OTHERS

The Supreme Court held that an assessee must exhaust statutory remedies before appealing directly under Article 136 of the Constitution of India against an assessment order. The Court emphasized that without final determination of facts by the assessing authority or invocation of High Court jurisdiction, the appeal is incompetent. This ruling aligns with precedents such as Mahadayal Premchandras v. Commercial Tax Officer Calcutta and The State of Bombay v. M/s. Ratilal Vedilal, reinforcing the principle that direct appeals to the Supreme Court are not ordinarily permissible in tax matters.