Rectification must be decided by a speaking order with personal hearing when factual disputes are raised.

Rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 requires the authority to address objections by a reasoned speaking order, since power to correct an error apparent on the face of the record cannot be exercised by a bare assertion that no such error exists. Where the assessment dispute involves a factual basis challenge, fairness also requires a personal hearing. The rejection order was found inadequately reasoned and procedurally unfair, and the rectification petitions were set aside for fresh consideration in accordance with law.

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Issues: Whether rejection of the petitioner's application for rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 was sustainable when the authority did not pass a speaking order and no personal hearing was granted.

Analysis: Section 84(1) confers power to rectify an error apparent on the face of the record, and the authority was required to apply its mind to the objections raised rather than merely state that no such error existed. The impugned rejection did not disclose reasons showing why the case did not involve an apparent error, and the petitioner was also not afforded a personal hearing, despite a specific dispute on the factual basis of the assessment. In these circumstances, the order lacked adequate reasoning and fair consideration.

Conclusion: The rejection of the rectification petitions was set aside and the matter was remanded to the respondent for fresh consideration in accordance with law.

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