Writ jurisdiction against revisional show-cause notices is limited when objections can still be filed before assessment.

Writ jurisdiction will ordinarily not be exercised to quash a revisional show-cause notice under Section 27 of the Tamil Nadu Value Added Tax Act when the notice grants an effective opportunity to file objections and no exceptional ground for immediate interference is shown. The challenge to the proposed revision, including objections on the rate of tax and the basis of the proposal, is to be considered by the assessing authority after the petitioner responds. In the absence of grave injustice, violation of fundamental rights, or breach of natural justice, the proper course is to submit objections and await a reasoned order in accordance with law.

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Issues: Whether writ jurisdiction should be exercised to quash revision notices issued under Section 27 of the Tamil Nadu Value Added Tax Act when the notices afforded an opportunity to file objections and the petitioner had not yet availed that remedy.

Analysis: The notices proposed revision of assessment and contemplated further action only after consideration of objections. The petitioner was given an opportunity to respond, and no grave injustice, violation of fundamental rights, or breach of natural justice was shown so as to justify interference at the notice stage. The grievance regarding the rate of tax and the basis of the proposal was held to be a matter for adjudication by the assessing authority after objections were filed.

Conclusion: The writ petitions were not entertained on merits at the notice stage, and the petitioner was directed to file objections before the respondent, who was then to consider them and pass orders in accordance with law.

Ratio Decidendi: A writ petition will ordinarily not be entertained against a revisional show-cause notice when an effective opportunity to file objections is available and no exceptional ground justifying immediate interference is established.

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