THANSINGH NATHMAL AND ORS. vs A. MAZID, SUPERINTENDENT OF TAXES

The Supreme Court held that the appellants' challenge to the validity of the Explanation to Section 2(12) of the Assam Sales Tax Act, 1947, was not maintainable as they failed to seek a reference to the High Court under Section 32 of the Act. The Court emphasized that the High Court does not entertain writ petitions under Article 226 when an alternative remedy exists, and it does not act as an appellate authority over factual determinations made by taxing authorities. The appeal was restricted to questions of law certified by the High Court, and leave under Article 132(3) was refused.