Revision notice must state reasons for reopening completed assessment; repeated proposals without grounds are legally defective.

A revision notice proposing reassessment and penalty under the Tamil Nadu Value Added Tax Act, 2006 must disclose why completed assessments are sought to be reopened; a mere repetition of an earlier proposal without reference to the prior assessment or the grounds for revision is legally defective. Although the assessing authority may revise an assessment within limitation, the notice cannot proceed as a fresh original proposal ignoring earlier proceedings. On that basis, the impugned notice was unsustainable in law and liable to be withdrawn, while liberty remained to issue a fresh notice in accordance with law.

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Issues: Whether the impugned notice proposing revision of assessment and penalty under the Tamil Nadu Value Added Tax Act, 2006 was sustainable when it merely repeated the earlier proposal without disclosing reasons for revising the assessment already completed.

Analysis: The notice of proposal issued earlier had already been replied to, and assessment orders were thereafter passed for the relevant years. The impugned notice repeated the same allegations in the same terms as the earlier proposal, without referring to the prior assessment or stating the grounds on which revision was sought. Though the assessing authority has power to revise assessment within limitation, a revision notice must disclose the reasons necessitating such revision and cannot be issued as a fresh original proposal ignoring the earlier proceedings. The absence of such reasons made the impugned notice legally defective.

Conclusion: The impugned notice was unsustainable in law and was liable to be withdrawn, though liberty was preserved to issue a fresh notice in accordance with law.

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