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Issues: Whether the writ petitions challenging the revision notices under the Tamil Nadu Value Added Tax Act, 2006 were maintainable at the stage of notice, and whether the respondent should be directed to consider the petitioner's objections independently and uninfluenced by the Enforcement Wing report.
Analysis: The notices called for objections and offered a personal hearing before any order was passed. The petitioner's grievance, including the challenge to the reliance on the Enforcement Wing report and the proposed disallowance of input tax credit and exemption claims, was held to be a matter for consideration before the assessing authority in the first instance. The existence of an opportunity to file objections meant that the petitioner ought to pursue the statutory course before invoking writ jurisdiction. The Court found no grave injustice or violation of fundamental rights at the notice stage, and held that the authority must decide the objections on merits with an independent mind and without being influenced by the Enforcement Wing report.
Conclusion: The writ petitions were not entertained on merits at the notice stage; the petitioner was directed to file and have its objections considered by the respondent, who was required to afford a hearing and pass fresh orders in accordance with law.
Ratio Decidendi: Where a pre-assessment or revision notice grants an opportunity to object, writ jurisdiction will ordinarily not be exercised to quash the notice, and the assessing authority must first decide the objections independently and in accordance with law.
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