Revisional jurisdiction under VAT law cannot fully assess new factual material; remand granted for fresh consideration.

The Madras HC held that revisional jurisdiction under Section 51 of the Puducherry Value Added Tax Act, 2007 does not permit full factual adjudication on new material not raised before the lower authorities. Because the later Supreme Court ruling could affect entitlement to input tax credit and the treatment of inter-State sales to Government Departments, the petitioner was given a further opportunity to raise additional grounds and support them with relevant decisions. The Tribunal's order was set aside and the matter remanded for fresh consideration on merits in accordance with law.

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Issues: Whether the revision should be allowed and the matter remanded to the Tribunal for fresh consideration in view of the later Supreme Court ruling and the need to examine the factual and legal contentions afresh.

Analysis: The Court noted that the contention based on the later Supreme Court decision had not been raised before the lower authorities and that the revisional jurisdiction under Section 51 of the Puducherry Value Added Tax Act, 2007 did not permit a full factual adjudication on the new material. As the later decision may bear on the entitlement to input tax credit and the treatment of inter-State sales to Government Departments, the petitioner was held entitled to a further opportunity before the Tribunal to raise additional grounds and support them with relevant decisions.

Conclusion: The revision was allowed, the Tribunal's order was set aside, and the matter was remanded to the Tribunal for fresh consideration on merits in accordance with law.

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