Revision of a finalised assessment lacked jurisdiction where the assessment had already been validly revised and attained finality.

An assessing officer had no jurisdiction under section 84 of the Tamil Nadu Value Added Tax Act, 2006 to revise an assessment order that had already been revised and had attained finality. The original assessment under the Central Sales Tax Act, 1956 was revised on the assessee's request after production of Form C declarations, with credit granted and tax liability modified. Because that revised order had become final, the later notice could not lawfully reopen it under section 84. The impugned revision was therefore without jurisdiction and liable to be quashed.

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Issues: Whether the assessing officer had jurisdiction under section 84 of the Tamil Nadu Value Added Tax Act, 2006 to revise an assessment order that had already been revised and had attained finality.

Analysis: The assessment for the relevant year had been completed under the Central Sales Tax Act, 1956 and was thereafter revised on the assessee's request after production of form C declarations. The revised order granted credit where declarations were produced and modified the tax liability, and that order attained finality. The later notice sought to revise the already revised assessment. The statutory power under section 84 of the Tamil Nadu Value Added Tax Act, 2006 did not authorise the assessing officer to revise his own assessment order in these circumstances.

Conclusion: The impugned revision was without jurisdiction and was liable to be quashed in favour of the petitioner.

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