4.In my considered view, the issues raised by the petitioner are not purely legal issues but the issues which require both factual and legal aspects which has to be gone into. Therefore, the petitioner has to necessarily avail the remedy provided under the Act. It is not disputed that as against the impugned order, a revision lies to the Joint Commissioner of the concerned jurisdiction and therefore, the petitioner has to first avail such a remedy and raise all contentions before the revisional authority before resorting to invoking the extraordinary remedy before this Court in Article 226 of the Constitution of India. For such reason, this Court not inclined to entertain the writ petition but would grant liberty to the petitioner to file a revision petition before the concerned revisional authority and if such a revision petition is filed within 15 days from the date of receipt of a copy of this order, the revisional authority shall decide the writ petition on merits and in accordance with law after affording an opportunity of personal hearing to the petitioner within a period of four weeks from the date on which the personal hearing is concluded. It is made clear that the petitioner is entitled to raise all factual and legal issues before the revisional authority.
