ORDER A. R. Tiwari, J. - This is a petition under article 226 of the Constitution of India. Briefly stated the facts of the case are that the petitioner, a firm engaged in sale of bidi as sole selling agent in Madhya Pradesh, is assessed to entry tax for the years 1989-90, 1990-91, 1991-92, 1992-93, 1993-94 (annexures P/1 to P/5). Aggrieved, it preferred appeals impugning these orders (annexures P/6 to P/10) before respondent No. 5 (Appellate Deputy Commissioner). Respondent No. 5 dismissed the appeals on December 6, 1994 (annexures P/6 A to P/10 A). Appellate orders were served on February 1, 1995. The apex Court decided in [1994] 95 STC 5 (Entry Tax Officer v. Chandanmal Champalal & Co.) that goods brought or sold in the local area, if exported outside the area, are immune from levy of entry tax. Respondent No. 4, (Sales Tax Officer) equipped with powers of Tehsildar for the purposes of recovery of dues, issued demand notices (annexures P/22 to P/25) under section 146, Madhya Pradesh Land Revenue Code and later notices dated January 30, 1995 (annexures P/26 to P/29) under section 22(6) of M.P. General Sales Tax Act, 1958 to deposit the dues in seven days. Petitioner questioned validity of these notices on the ground of prematurity (annexures P/30, P/31). Respondent No. 4 also ordered attachment of bank accounts of the petitioner with respondent Nos. 6 to 8 (annexures P/32 to P/34). Petitioner seeks quashment of orders of assessment, recovery notices and attachment of bank accounts. Respondents Nos. 1 to 5 oppose the prayer. Petitioner is shown to be liable to pay the sum as entry tax for the years 1989-90, 1990-91, 1991-92, 1992-93 and 1993-94 quantified at Rs. 29,32,223. This petition, however, is related to the liability of about Rs. 19 lacs. Respondents Nos. 6 to 8 have informed the respondent No. 4 that balances in bank accounts were below Rs. 2,000 in each account. Attachment thus turns out to be acarpous. Rule 57-A of the Madhya Pradesh General Sales Tax Rules, 1959 provides for stay of recovery of the remaining amount pending decision of the appeal. Rule 37 grants the period of "thirty days" from the date of service of orders passed under section 38 or 39 of the aforesaid Act. Article 265 of the Constitution of India mandates that "no tax shall be levied or collected except by authority of law". Rule 37 grants the period of "thirty days" from the date of service of orders passed under section 38 or 39 of the aforesaid Act. Article 265 of the Constitution of India mandates that "no tax shall be levied or collected except by authority of law". It is thus clear that "collection" too must be in conformity with law. Learned counsel for the petitioner placed reliance on the decisions reported in [1991] 81 STC 269 (MP); 1989 CUR TJ 155 (Mulay Brothers v. State of M.P.) and [1988] 68 STC 308 (MP); 1988 CUR TJ 603 (Keveyan & Co. v. G. S. Bagehal) and prayed for the direction to respondents to make fresh assessment after reasonable opportunity of hearing to the petitioner and for cancellation of notices and for release of the bank accounts. The Government Advocate, on the other hand, submitted that the petition is without valid cause and remedy if any lies under the relevant Act. He also submits that benefit of period prescribed under the rule 37 is not available to the petitioner because the appellate authority neither made interference nor quantified any amount. According to him, it was simply a case of dismissal of the appeals. As regards the challenge to the orders of assessment, it is admitted before me that alternative remedy of revision is available. In AIR 1994 SC 754 (State of U.P. v. Labh Chand) it is held as under : "When a Statutory Forum or Tribunal is specially created by a statute for redressal of specified grievances of persons on certain matters, the High Court should not normally permit such persons to ventilate their specified grievances before it by entertaining petitions under article 226 of the Constitution is a legal position which is too well-settled." In [1994] 94 STC 190 (SC); AIR 1994 SC 2377 (State of Andhra Pradesh v. T.G. Lakshmaiah Setty and Sons) it is held that : "The validity of an assessment order must be tested in an appeal or revision filed by an assessee as provided for in the Act and in no other way." Whether the goods have been sent outside the area or not is also a question of fact. In such matters, the adjudication should better be left to the departmental authority. In such matters, the adjudication should better be left to the departmental authority. In [1993] 90 STC 477 (SC); AIR 1994 SC 1697 (K.B. Handicrafts Emporium v. State of Haryana) it is held that : "We must make it clear that in a petition under article 32 of the Constitution, it is not our province to go into facts. As repeatedly emphasised by this Court, the question whether a particular sale is an intra-State sale, an inter-State sale, an export sale within the meaning of section 5(1) or a penultimate sale within the meaning of section 5(3), or otherwise, is always a question of fact to be decided by the appropriate authority in the light of the principles enunciated by courts. In these circumstances, we content ourselves by declaring the law and leave it to be applied by the appropriate authorities. Counsel for the petitioners says that all the sales effected by all the petitioners are inter-State sales. May be, or may not be. We leave the matters to be disposed of by the authorities under the Act in the light of the law declared by this Court." It is also held in AIR 1992 SC 2279 (Shyam Kishore v. Municipal Corporation of Delhi) that recourse to writ jurisdiction is not proper when more satisfactory solution is available on the terms of the statute itself. In view of the aforesaid position, decisions relied upon by the counsel for the petitioner are not helpful to the petitioner. In the result, I decline examination of the assessment orders and as such decline interference leaving the petitioner free to take recourse under the relevant Act. As regards the question of validity of notice in the face of rules 57-A and 37 of the M.P. General Sales Tax Rules, 1959, I find it unnecessary to examine that question because very small period is left even according to the contention of the petitioner. In the circumstances, I find it fit to dispose of this petition with the directions as under : (a) Demand notice (annexures P/22 to P/25; P/26 to P/29) are quashed with liberty to respondent No. 4 to proceed further in the matter in accordance with the law after the expiry of 30 days from February 1, 1995, the date of service of the appellate order on the petitioner. (b) The orders of attachment of bank accounts (annexures P/32 to P/35) are also quashed because in any case the bank balance in respect of the accounts make the orders unfruitful. The petitioner is granted liberty to resort to appropriate remedy against the orders of assessment in conformity with law as noted above. With the aforesaid directions, this petition stands finally disposed of without any order as to costs. Writ petition disposed of accordingly.