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Issues: Whether the writ petition should be entertained against the revised assessment order in view of the availability of the statutory appeal under the Tamil Nadu Value Added Tax Act, 2006, and whether the principle concerning invoice-wise verification in mismatch matters compelled interference.
Analysis: The impugned assessment was passed after objections and dealt with only certain confirmed heads, while the petitioner had not produced the supporting material sought for the claim relating to return of goods. The reasoning invoked in the earlier mismatch decision was held distinguishable because that case involved an assessment proceeding based solely on third-party annexures without the same factual matrix. In fiscal matters, the availability of an efficacious statutory appeal was treated as a strong reason to decline writ intervention, and the appellate authority was noted to be the proper forum to examine factual issues such as invoice-wise break-up and supporting documents.
Conclusion: The writ petition was not entertained on merits and the petitioner was relegated to the statutory appellate remedy under the Tamil Nadu Value Added Tax Act, 2006.