Rectification for omitted C-forms is unavailable under the tax statute; the statutory appeal remained the proper remedy.

Omission to consider C-forms and related material was held not to be rectifiable under Section 84 of the Tamil Nadu Value Added Tax Act, 2006, because the provision is confined to errors apparent on the face of the record and does not permit reopening assessment controversies; the proper remedy lies in appeal. In a fiscal matter, the writ petitions were also declined because an efficacious statutory appeal under Section 51 was available, no exceptional ground for bypassing that remedy was shown, and the dispute was already in a second round of litigation. The challenge was therefore relegated to the appellate forum and the rectification request rejected in substance.

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Issues: (i) Whether omission to consider the C-forms and related material could be corrected by rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006. (ii) Whether the writ petitions should be entertained despite the statutory appeal under Section 51 of the Tamil Nadu Value Added Tax Act, 2006.

Issue (i): Whether omission to consider the C-forms and related material could be corrected by rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006.

Analysis: Section 84 is confined to rectifying errors apparent on the face of the record. The provision is intended to correct inadvertent mistakes and not to reopen assessment controversies on the basis that materials or claims placed before the assessing authority were not considered. A grievance of non-consideration of C-forms or similar materials belongs to the appellate domain and does not amount to rectification in the statutory sense.

Conclusion: The plea did not fall within Section 84 and was not maintainable as a rectification request.

Issue (ii): Whether the writ petitions should be entertained despite the statutory appeal under Section 51 of the Tamil Nadu Value Added Tax Act, 2006.

Analysis: The dispute arose under a fiscal statute where the statutory appellate remedy was available and effective. The rule against bypassing alternate remedies applies with greater rigour in revenue matters, and writ jurisdiction is not normally invoked unless a recognised exception exists. No jurisdictional defect, non-operational appellate forum, or other exceptional circumstance was shown. The matter was also in a second round of litigation, which further supported resort to the statutory appeal.

Conclusion: The writ petitions were not entertained and the petitioner was directed to pursue the statutory appeal remedy.

Final Conclusion: The challenge to the impugned assessments was not examined on merits, as the controversy was relegated to the statutory appellate forum and the request for rectification was rejected in substance.

Ratio Decidendi: A claim that an assessing authority failed to consider materials such as C-forms cannot be treated as rectification of an error apparent on the face of the record, and in fiscal matters the writ court will ordinarily decline interference where an efficacious statutory appeal is available and no exceptional ground is made out.

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