ORDER D. V. SHYLENDRA KUMAR, J. - Petitioner is an assessee under the provisions of the Karnataka Sales Tax Act, 1957 (for short, "the Act"). Petitioner has been assessed to certain tax liability for the accounting period 2003 and 2004 dated December 27, 2004 as per annexure A. Petitioner is disputing the liability to tax under this order on the premise that while assessing, the petitioner has not been extended the various concessions that has been extended to persons like petitioner on the basis of various Government Orders that had been issued from time to time particularly G.O. No. CI 30 SPC 96, dated March 15, 1996 package of incentives and concessions for the years 1996 to 2001; that in terms of the concessions given under this notification for the kind of business that the petitioner is carrying. The petitioner contends that it is entitled for such benefit for a period of six years from the date of production; that the assessing authority has not extended this benefit in view of a subsequent Notification No. CI 30 SPC 96, dated March 15, 1996 package of incentives and concessions for the years 1996 to 2001; which is a notification under section 19C of the Act granting exemption, etc. Submission of Sri M. N. Shankaregowda, learned counsel for the petitioner is that the subsequent notification is at variance with the earlier notification. In view of the subsequent notification being at variance, persons like the petitioners who could have got the concession on establishing industries or setting up their units are deprived of the benefit which the earlier notification had promised and that portion of the subsequent notification which is inconsistent with the earlier G.O. requires to be quashed. Petitioner is approaching this court in the context of determination of certain liability fastened by the assessing officer. It is the submission of the learned counsel that the assessment order in turn relies on the subsequent notification of the Government dated March 15, 1996 annexure E and not under the earlier G.O. To this extent the liability is sought to be disputed and that there is no use for the petitioner to urge the contentions about the validity or otherwise of a notification before the statutory functionaries and that is the reason as to why petitioner has sought to avail writ jurisdiction. In so far as the argument that the subsequent notification to such extent is bad is concerned, it is rather difficult for me to accept this argument at this stage while exercising writ jurisdiction. In the first instance the question as to the latter notification if to any extent is at variance with the former Government Order is to be examined, i.e., the question as to the exemption notification issued under section 19C of the Act is not in consonance with the earlier policy statement of the Government and the benefits promised under that, has to be examined. In so far as the incentives provided to new industrial units set up in notified areas and also additional investments in such units are concerned even the policy statement extending sales tax concessions to new units is concerned as indicated in clause (d) of sales tax concession at item 5 of the different items of concessions/benefits, itself indicates the manner in which additional production attributable to additional investment is to be computed, which additional production alone enjoys the tax concession and a reading of the exemption notification dated November 15, 1996 issued under section 19C of the Act, prima facie indicates that the subsequent notification seeks to extend the benefit of exemption to the additional production attributable to the additional investments. Computed on the same basis as had been indicated in the earlier Government Policy statement. That is to say the restriction if any as understood by the petitioner said to be present in the latter notification is not, a restriction brought in by the notification dated November 15, 1996 but a restriction or to be precise the mode of computation of the tax concession as had been indicated even in the policy statement of the Government issued in terms of the G.O. dated March 15, 1996. Whether the benefit of exemption is correctly extended to the petitioner if available for the period in question, in terms of the assessment order or not necessarily involves the examination of the question of proper application of the exemption notification to the facts of the petitioner's case, an exercise best left to be undertaken by the appellate authority under the Act, even if the assessment order requires any correction. It is because of this reason I am not inclined to examine the merits of the contentions urged by the learned counsel for the petitioner at this stage and would leave the petitioner to avail of the statutory remedies under the Act itself. The learned counsel for the petitioner has relied on the following decisions in support of his submission : 1. Brooke Bond Lipton India Limited v. State of Karnataka [1998] 109 STC 265 (Karn). 2. State of Bihar v. Suprabhat Steel Ltd. [1999] 112 STC 258 (SC). 3. Wipro Infotech Limited v. Additional Deputy Commissioner of Commercial Taxes (Assessment - II) [2000] 117 STC 244 (Karn). In Brooke Bond's case [1998] 109 STC 265 (Karn), I notice that the matter had been brought before the High Court through the hierarchy of the authority under the Act. Petitioner wants to by-pass this cause in spite of an enabling provision to file an appeal, wants to approach this court directly. As indicated above, I am not inclined to examine such questions under writ jurisdiction. In the case of State of Bihar v. Suprabhat Steel Ltd. [1999] 112 STC 258 (SC) what has been laid down is that any express benefit issued to a dealer cannot be taken away mid way after the assessees have acted on the basis of a notification which had granted the specific benefit. In the present case, I notice that the policy statement of the Government had come to be issued in November, 1996, the dispute had arisen in the year 2003 and 2004. The exemption notification issued in November, 1996 has held the field all along and it is not as though the petitioner was not aware of this question. In fact in the present case, the exemption notification came to be issued subsequently which alone determines the tax liability for the purpose of assessment by the assessing authority under the Act. In so far as the decision in the case of Wipro Infotech Limited v. Additional Deputy Commissioner of Commercial Taxes (Assessment - II) [2000] 117 STC 244 (Karn) is concerned, the contention was as to whether a valuation by the FAVC issued by the Industries and Commerce Department is binding on the parties. In so far as the decision in the case of Wipro Infotech Limited v. Additional Deputy Commissioner of Commercial Taxes (Assessment - II) [2000] 117 STC 244 (Karn) is concerned, the contention was as to whether a valuation by the FAVC issued by the Industries and Commerce Department is binding on the parties. Such a question does not arise in this case, assuming it arises it is for the petitioner to seek answer before the appellate authority under the Act and not before this court in writ jurisdiction under articles 226 and 227 of the Constitution. It is for the assessee to take up such matters in appeal when appellate remedies are provided under the Act. No need for this court to interfere with the assessment order. Writ petition is dismissed.