As per case facts, petitioners challenged assessment notices for tax and penalty under the VAT Regulation, arguing they were time-barred, exceeded jurisdiction, and violated natural justice by lacking prior hearings ... and being vague. Respondents argued that an alternative remedy, a functional Appellate Tribunal, existed and that limitation periods were affected by the late notification of VAT Rules and a grace period for filing returns. The question arose whether the Writ Petition should be entertained despite an alternative remedy, particularly concerning issues of limitation and natural justice. Finally, the High Court declined to entertain the Writ Petitions, finding limitation a mixed question of fact and law, not purely jurisdictional here, and noting petitioners had already pursued statutory objections. It concluded no breach of natural justice occurred due to available post-decisional hearings. Cases filed before August 19, 2025, when the Tribunal became functional, are transferred to it without requiring pre-deposit. Cases filed afterward are dismissed, with petitioners free to approach the Tribunal.