Revision rejected on limitation directed to be heard on merits under Tamil Nadu VAT revision procedure

A revision rejected solely on limitation under Section 54(1) of the Tamil Nadu Value Added Tax Act, 2006 was directed to be entertained if the papers were in order and decided on merits. The court did not adjudicate the underlying assessment dispute in these writ petitions and declined to pursue the limitation objection further. The practical effect was that the revisional authority had to receive and dispose of the revision in accordance with law, with the matter sent back for merits-based consideration rather than being barred at the threshold.

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Issues: Whether the revisional authority was justified in rejecting the revision on the ground of limitation, and whether the revision should be entertained and decided on merits.

Analysis: The revision was rejected solely for delay by invoking the limitation prescribed under Section 54(1) of the Tamil Nadu Value Added Tax Act, 2006. The Court found it sufficient to direct the revisional authority to entertain the revision if the papers were in order and to decide it on merits, without going into the question of limitation. The original assessment controversy was not adjudicated in these writ petitions.

Conclusion: The objection on limitation was not sustained, and the revisional authority was directed to receive and dispose of the revision on merits in accordance with law.

Final Conclusion: The petitioners obtained relief against the rejection of revision, and the matter was sent back for consideration on merits without enforcing the limitation objection.

Ratio Decidendi: Where a revision is declined only on limitation grounds, the revisional authority can be directed to entertain and decide it on merits if the court deems such course appropriate.

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