Cross-verification before reassessment is mandatory where departmental mismatch is relied on; order quashed and remanded.

A reassessment based on a mismatch in departmental records cannot be sustained unless the authority follows the prescribed cross-verification procedure with the other-end dealer and gives a proper hearing. Here, the reopening of a deemed assessment under the Tamil Nadu VAT Act was procedurally defective because the discrepancy was not meaningfully verified and the petitioner's supporting material was not properly considered. The impugned order was quashed and the matter was remitted for fresh consideration after notice and compliance with the required procedure.

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Issues: Whether the reassessment order based on mismatch reflected in the departmental website could be sustained without following the procedure of verifying the discrepancy with the other-end dealer and granting a proper hearing.

Analysis: The assessment had been completed on a deemed assessment basis under Section 22(2) of the Tamil Nadu Value Added Tax Act. The reopening was founded on a mismatch noticed during inspection and in the departmental records, but the authority did not follow the procedure requiring enquiry with the other-end dealer as laid down in the governing precedent. The petitioner also placed material in support of its defence, which was not dealt with in a meaningful manner. In these circumstances, the assessment process was found to be procedurally defective.

Conclusion: The impugned order could not be sustained and was quashed. The matter was remitted to the assessing authority for fresh consideration after issuing notice and following the prescribed procedure.

Final Conclusion: The petitioner obtained setting aside of the assessment order and a fresh adjudication on remand, while the demand was not finally deleted and further proceedings were left open before the authority.

Ratio Decidendi: Where a completed assessment is reopened on the basis of a mismatch in departmental records, the authority must follow the prescribed cross-verification procedure and give a proper hearing before confirming liability.

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