Parallel tax assessments for the same years were set aside and remanded when the later authority acted without notice of earlier orders.

Subsequent revision assessments under the Tamil Nadu Value Added Tax Act were interfered with because the same assessment years had already been assessed by the original assessing officer, and the later authority proceeded without awareness of those earlier orders. The Madras HC treated the matter as involving parallel proceedings and set aside the revision assessment orders, remanding them for fresh consideration by the proper authority. The separate penalty order was also set aside consequentially, but the penalty challenge was not examined on merits and remained open.

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Issues: Whether the revision assessment orders passed under section 22(5) of the Tamil Nadu Value Added Tax Act, 2006 were liable to be interfered with on the ground that identical assessment years had already been assessed by another authority, and whether the separate penalty order could survive after the assessment orders were set aside.

Analysis: The impugned revision assessments were made for the same assessment years in respect of which earlier assessments had already been completed by the original assessing officer. The subsequent authority acted without being apprised of the earlier orders, and the proceedings were therefore treated as parallel proceedings requiring interference. Since the assessment orders were set aside, the separate challenge to the penalty order was not examined on its merits and was left open.

Conclusion: The revision assessment orders were set aside and remanded for fresh consideration. The penalty order was also set aside consequentially, without adjudication on the merits of the penalty issue.

Final Conclusion: The petitioner obtained relief against the impugned tax orders, with the matters sent back for reconsideration by the proper authority and the penalty challenge left undecided on merits.

Ratio Decidendi: Where a subsequent tax revision is made for assessment years already covered by earlier assessments, and the later authority proceeds without awareness of the earlier orders, the resulting proceedings are liable to be interfered with and remanded for fresh consideration.

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