Petitioner to Challenge Advance Ruling, Authority to Review, Await Decision

The court directed the petitioner to file a review petition challenging the applicability of the Advance Ruling within two weeks, providing evidence of how the ruling does not apply to their products. The Advance Ruling Authority was instructed to consider the petition, give notice to the petitioner and assessing officer, and pass appropriate orders within four weeks. Further proceedings based on the assessment orders were suspended pending the Authority's decision. The writ petitions were disposed of with no costs, emphasizing the proper procedure for challenging an Advance Ruling under the TNVAT Act.

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Issues:
Challenge to assessment orders under TNVAT Act for multiple years based on reliance on Advance Ruling.

Analysis:
The petitioner, a registered dealer under TNVAT Act, challenged assessment orders for various years, contending that the assessing authority erred by relying solely on an Advance Ruling obtained by another entity. The petitioner argued that the authority's reliance on the ruling was incorrect, citing precedents where it was held that the Commissioner lacks power to issue clarifications on tax rates and circulars lack legal authority. However, the court clarified that the 2.12.2013 proceedings were not a clarification or circular but an exercise of power by the Authority for Clarification and Advance Ruling under Section 48-A of the TNVAT Act.

The court directed the petitioner to file a review petition challenging the applicability of the Advance Ruling within two weeks, providing evidence of how the ruling does not apply to their products. The Advance Ruling Authority was instructed to consider the petition, give the petitioner and assessing officer notice, and pass appropriate orders within four weeks from the filing date. Until the Authority's decision, further proceedings based on the assessment orders were to be suspended.

In conclusion, the writ petitions were disposed of with no costs, and connected miscellaneous petitions were closed. The judgment emphasized the proper procedure for challenging an Advance Ruling under the TNVAT Act, highlighting the role and powers of the Advance Ruling Authority in reviewing, amending, or revoking rulings for good cause after giving affected parties an opportunity to be heard.

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