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Issues:
- Jurisdiction of civil court under section 62 of the Tamil Nadu Agricultural Income Tax Act, 1955. Analysis: The case involved a dispute where the plaintiff sought relief from an assessment made under the Tamil Nadu Agricultural Income Tax Act, 1955. The plaintiff claimed that post a registered partition, his holdings were reduced, making him ineligible for assessment under the Act. The plaintiff filed a suit for declaration, injunction, and refund of the tax collected. The defendants contended that the civil court lacked jurisdiction as per section 62 of the Act. The trial court dismissed the suit, citing section 62 as a bar to civil court jurisdiction due to the Act being a self-contained code. The lower appellate court, however, held that the civil court had jurisdiction, emphasizing that the authorities should have considered the partition deed before assessment. The lower appellate court decreed the suit, ordering a refund. The matter was appealed in the High Court. The High Court analyzed the jurisdictional issue in light of section 62 of the Act, which prohibits civil suits to set aside or modify assessments made under the Act. The Court noted that the Act provided a comprehensive mechanism for assessment, appeal, refund, and rectification of mistakes. Relying on Supreme Court precedents, the Court emphasized that when a statute creates specific rights and liabilities and provides a mechanism for adjudication, the civil court's jurisdiction is excluded by necessary implication. The Court cited the Kamtala Mills and Mafatlal Industries cases, which held that the Act's refund provisions create an exclusive remedy, barring civil suits for refund. The Court concluded that since the assessment was made under the Act, any challenge or claim for refund must be pursued through the Act's prescribed procedures, such as appeal, revision, or rectification. The plaintiff's failure to seek refund under the Act precluded the civil court's jurisdiction. Therefore, the High Court allowed the second appeal, setting aside the lower appellate court's judgment and dismissing the suit, with no order as to costs.
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