Compounding show cause notices under VAT law can be taken in revision on merits when no formal order has been passed.

Show cause notices for compounding of offence under the Tamil Nadu Value Added Tax Act, 2006 became spent after the detained goods were released on payment of the compounding amounts, although no formal compounding order had been passed. In that situation, the affected party was restored to the statutory revisional remedy, and the revisional authority was directed to take the revision petitions on file and decide them on merits after hearing both sides. The document underscores that where only notices exist and no compounding order has been made, the dispute may still be examined through revision on the factual merits.

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Issues: Whether the petitioner was entitled to challenge the show cause notices for compounding of offence after the release orders had been issued and whether the revision petitions should be entertained notwithstanding the refusal to receive them on limitation.

Analysis: The challenge arose from show cause notices issued for compounding of offence in respect of detained goods under the Tamil Nadu Value Added Tax Act, 2006. The goods were released after the petitioner paid the compounding amounts, but no formal compounding order had been passed. In these circumstances, the Court held that the notices had worked themselves out and that the petitioner should be permitted to pursue the revision remedy before the revisional authority, which could examine the factual dispute and decide the matter on merits after affording an opportunity of hearing.

Conclusion: The petitioner was permitted to represent the revision petitions before the Joint Commissioner, who was directed to take them on file and decide them on merits in accordance with law.

Final Conclusion: The writ petitions were disposed of by restoring the petitioner to the statutory revisional remedy for adjudication on merits.

Ratio Decidendi: Where no compounding order has been passed and only show cause notices have been issued, the affected party may be permitted to invoke the revisional remedy for a merits-based decision.

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