Rectification orders under VAT law are to be pursued in revision, with stay and limitation protection available.

Orders passed on rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 are treated as matters for revision under Section 54 rather than appeal. The High Court declined to pursue the appellate route in the writ proceedings and instead relegated the assessee to the revisional forum, permitting filing of stay applications there. It also directed the revisional authority to entertain the petitions without raising limitation objections, decide them on merits within the stipulated time, and keep recovery proceedings in abeyance pending consideration of stay.

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Issues: Whether an appeal lies against orders passed on rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006, or whether the proper remedy is revision under Section 54 of that Act.

Analysis: The petitioner challenged the return of appeal papers and contended that the impugned orders were consequential to the original assessment orders and therefore appealable. The respondents maintained that once the assessments were revised under Section 84, the remedy against such orders lay only in revision. The Court, instead of deciding the matter on the appellate route, treated the dispute as one that should be pursued before the revisional authority and permitted the petitioner to approach that forum with stay applications. It also directed the revisional authority to entertain the petitions without objection as to limitation and to decide them on merits within stipulated time, with interim protection against recovery proceedings pending consideration of stay.

Conclusion: The appeal remedy was not pursued in the writ proceedings, and the petitioner was relegated to the revisional remedy under Section 54 of the Tamil Nadu Value Added Tax Act, 2006.

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