Revision application under VAT law must be heard on merits with personal hearing before rejection.

An application for revision under Section 84 of the Tamil Nadu Value Added Tax Act, 2006, once pending before the authority, had to be examined on merits with consideration of the supporting documents and, if necessary, verification of the transaction, followed by a reasoned order after personal hearing. Although no violation of natural justice was made out in the assessment proceedings because the dealer had not replied to the pre-revision notice, the pending revision application could not be rejected summarily. Fresh consideration of the Section 84 application on merits was directed.

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Issues: Whether the petitioner's application under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 was required to be considered on merits with an opportunity of hearing, instead of being rejected summarily.

Analysis: The petitioner had not replied to the pre-revision notice, so a plea of violation of natural justice in the assessment proceedings was not made out. However, an application seeking revision of the assessment had already been filed under Section 84 of the State Act and was pending. In such a situation, the authority was required to examine the application effectively, consider the documents produced, verify the genuineness of the transaction if necessary, and pass a reasoned order after granting personal hearing.

Conclusion: The petitioner was entitled to a direction for fresh consideration of the Section 84 application on merits with personal hearing, and the summary rejection of that application was not warranted.

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