Corrective tax jurisdiction requires independent consideration and reasons; mere concurrence with the assessment is invalid.

Section 16D of the Tamil Nadu General Sales Tax Act was treated as a corrective jurisdiction requiring independent scrutiny of an assessment alleged to be arbitrary or contrary to natural justice. The Committee had to consider the assessee's objections on its own merits, apply its mind to the material, and record reasons for accepting or rejecting the request; it could not merely endorse the assessing authority's view. A bare, non-speaking concurrence did not satisfy that statutory duty, so the rejection order was unsustainable, was set aside, and the matter was remitted for fresh consideration after hearing the petitioner.

---

---

Issues: Whether the Committee, while exercising jurisdiction under section 16D of the Tamil Nadu General Sales Tax Act, 1959, was required to independently consider the assessee's objections and give reasons before rejecting the application.

Analysis: Section 16D confers corrective jurisdiction on the Special Committee to examine assessments made in violation of the Act, the Rules, or the principles of natural justice, and to pass appropriate orders, including directing a fresh assessment. Where an assessee invokes this remedy on the ground that the assessment is arbitrary or passed without independent consideration of the objections, the Committee cannot dispose of the matter by merely endorsing the assessment or adopting the assessing authority's view. It must apply its own mind to the materials, examine the issues raised, and record reasons for either accepting or rejecting the request. A bare order of agreement does not satisfy the statutory duty when the power is meant to operate as a corrective mechanism.

Conclusion: The impugned rejection order was unsustainable for want of independent consideration and reasons, and it was set aside.

Final Conclusion: The matter was remitted to the Committee for fresh consideration after giving the petitioner an opportunity of hearing.

Ratio Decidendi: An authority exercising corrective statutory jurisdiction must independently consider the objections raised, apply its mind to the relevant material, and pass a reasoned order; a non-speaking order of mere concurrence is invalid.

---