Limited supervisory jurisdiction under sales tax law cannot replace appellate review where no natural justice breach is shown.

Section 16D of the Tamil Nadu General Sales Tax Act confers only limited supervisory jurisdiction to correct patent illegality, a statutory bar, or a breach of natural justice, and it is not a substitute for appellate review on the merits. The challenge concerned the applicability of section 3(3) and entitlement to issue form XVII for consumables, but that dispute was held to fall within the statutory appellate remedy rather than supervisory interference. The record also showed no denial of opportunity or other natural justice violation. On that basis, the Special Committee was justified in declining to examine the assessment on merits, and interference with the assessment order was not warranted.

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Issues: Whether the Special Committee was justified in declining to interfere under section 16D of the Tamil Nadu General Sales Tax Act, 1959, and whether the impugned assessment order suffered from any jurisdictional error or violation of natural justice warranting interference.

Analysis: Section 16D confers a limited supervisory jurisdiction intended to correct patent illegality, statutory bar, or violation of natural justice. It is not an appellate substitute for reappreciation of merits. The challenge to the assessment primarily involved the applicability of section 3(3) and entitlement to issue form XVII for consumables, which was a matter falling within the statutory appellate remedy. The record also disclosed no denial of opportunity or breach of natural justice.

Conclusion: The Special Committee rightly refused to examine the matter on merits under section 16D, and no interference with the assessment order was called for.

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