Discuss (b) mandamus for refund

Procedure) The function first: judicial control polices the administration's OUTER LIMITS — jurisdiction, legality, natural justice, proportionality. The court does not sit as a tax assessor: it checks whether the officer stayed inside the statute, heard the taxpayer, and reasoned — the HOW, not the HOW MUCH. The map's logic: administrative remedies first, the tribunal next, the writ and appellate jurisdiction above. (a) Jurisdiction (the layers, in order) Departmental review/revision (the internal layer): the department's own hierarchy correcting officers' errors on the taxpayer's application — cheap and quick; the price: the collector reviewing the collector; The Revenue Tribunal (the statutory appeal forum): appeals from assessments, penalties and recovery orders under the tax Acts — composed to combine judicial and revenue expertise; its decisions appealable to the Supreme Court under the appellate route. Its specialization is its virtue: tax litigation's technical mass needs a forum that speaks the language; The Supreme Court's appellate jurisdiction: appeals from the Tribunal (the law's questions carried upward); The writ jurisdiction (the constitutional layer): the High Courts under Article 144 and the Supreme Court under Article 133 — where no effective remedy exists, or where the action is unconstitutional. In tax practice: certiorari against ultra vires assessments, mandamus to compel refunds and duty-performance, prohibition against proceedings without jurisdiction — and the public-interest tax litigation that has…