Writ interference in reassessment declined where dealer admitted omissions and statutory appeal remained available.

Reassessment under the Tamil Nadu VAT Act was challenged in writ jurisdiction on the basis of a web-report mismatch and the dealer's explanation, but the court confined its scrutiny to the legality of the decision-making process and not the merits of the assessment. The dealer's partner had admitted omissions during personal hearing and undertook to pay the differential tax. In these circumstances, no ground was found to interfere with the reassessment order, and the statutory appeal remedy was left open. Writ interference was therefore declined.

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Issues: Whether the impugned reassessment order under Section 27 of the Tamil Nadu Value Added Tax Act, 2006 called for interference in writ jurisdiction when the dealer's partner had admitted liability during the proceedings and a statutory appeal was available.

Analysis: The challenge was directed against the reassessment made on the basis of web-report mismatch and the dealer's subsequent explanation. The writ court was not to sit as an appellate authority over the assessment on merits, but to examine only the legality of the decision-making process. The record showed that during personal hearing the dealer's partner had accepted omissions and undertook to pay the differential tax. In these circumstances, the court found no ground to interfere with the reassessment order and left open the remedy of a statutory appeal.

Conclusion: The challenge to the reassessment failed and interference under writ jurisdiction was declined.

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