Post-assessment representation treated as Section 84 application, with recovery stayed pending disposal.

A post-assessment representation may be treated as an application under Section 84 of the Tamil Nadu Value Added Tax Act, 2006, where the assessee seeks reconsideration after the assessment order. The assessing authority is to hear the petitioner and dispose of that Section 84 application within the stipulated time. To preserve the remedy's effectiveness, recovery action is to remain stayed until the application is decided.

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Issues: Whether the petitioner's post-assessment representation could be directed to be considered as an application under Section 84 of the Tamil Nadu Value Added Tax Act, 2006, and whether recovery ought to be kept in abeyance till such disposal.

Analysis: The petitioner had challenged the assessment order and relied on a subsequent representation made after the order. The Court treated that representation as one falling within Section 84 and fixed a time-limit for its disposal by the assessing authority. To preserve the efficacy of that remedy, the Court also directed that no recovery be pursued in the meantime.

Conclusion: The assessing authority was directed to dispose of the Section 84 application on or before the stipulated date after hearing the petitioner, and recovery was stayed until then.

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