Conditional reassessment opportunity granted where authenticated records may verify turnover despite failure to produce agreement copies.

Assessees who failed to produce agreement copies before completion of assessment under Section 27 of the Tamil Nadu Value Added Tax Act, 2006 were given a conditional opportunity to reopen the matter on merits. The Court noted that authenticated records from Government bodies were available and could be examined to verify turnover, but balanced that against the assessees' failure to respond to notices by requiring payment of 15% of the disputed tax for each assessment year within the stipulated time. On compliance, the assessment orders would be treated as show cause notices, objections and documents could be filed, and the assessments reconsidered; otherwise, the writ petitions would stand dismissed.

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Issues: Whether the assessees, who had not produced the agreement copies before completion of assessment under Section 27 of the Tamil Nadu Value Added Tax Act, 2006, were entitled to a further opportunity to file authenticated records and have the assessments reconsidered on payment of part of the disputed tax.

Analysis: The assessment orders had been passed after the assessees failed to respond to the notices and did not produce the requested agreement copies. At the same time, the record indicated that the assessees had undertaken substantial work for Government bodies and possessed other authenticated records from the concerned authorities. In that situation, the Court found that such records could be examined for verifying the correctness of the reported turnover. To balance the lapse on the part of the assessees with the need to examine the claims on merits, the Court imposed a condition that they pay 15% of the disputed tax for each assessment year within the stipulated time.

Conclusion: The assessees were granted a conditional opportunity to treat the assessment orders as show cause notices, file objections, produce authenticated documents, and secure reconsideration of the assessments on merits; failing compliance, the writ petitions would stand dismissed automatically.

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