Statutory rectification applications must be considered expeditiously; mandamus may issue without reaching the merits of assessment.

Where the grievance is confined to non-disposal of a statutory rectification application, the court may direct the assessing authority to consider it expeditiously in accordance with law without examining the merits of the assessment. The petition concerned a request under Section 22(6) of the Tamil Nadu Value Added Tax Act, 2006 to correct alleged mistakes in a self-assessment. Relief was limited to a mandamus for consideration of the pending application, and no adjudication was made on the assessment dispute itself.

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Issues: Whether a writ of mandamus should be issued directing the assessing authority to consider the petitioner's application under Section 22(6) of the Tamil Nadu Value Added Tax Act, 2006 and pass a fresh assessment order.

Analysis: The petition arose from a self-assessment for the relevant assessment year and an application seeking correction of mistakes in that assessment. The relief sought was limited to a direction for consideration of the rectification application. The respondent stated that, if no order had already been passed, the application would be considered in accordance with law. In these circumstances, the Court did not enter into the merits of the assessment dispute and confined the relief to a direction for expeditious consideration of the application, if it was in order and remained pending.

Conclusion: The petitioner was granted only a direction for consideration of the application under Section 22(6) of the Tamil Nadu Value Added Tax Act, 2006, and no adjudication was made on the merits of the assessment.

Final Conclusion: The writ petition was disposed of with a limited mandamus to the assessing authority to deal with the pending rectification request expeditiously in accordance with law.

Ratio Decidendi: Where the grievance is confined to non-disposal of a statutory rectification application, the Court may direct the authority to consider it expeditiously without examining the merits of the assessment.

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