Reasonable opportunity to show cause is mandatory before revision action; breach vitiates the order and requires fresh consideration.

A revision order under the Tamil Nadu Value Added Tax Act was set aside because no prior notice or reasonable opportunity to show cause had been given before action was taken. The court applied the common proviso to Section 27, which requires such opportunity before passing an order against the dealer. That breach of the statutory safeguard vitiated the impugned order, and the matter was directed to be reconsidered afresh after giving the required opportunity. The merits of the revision were not examined.

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Issues: Whether the impugned revision order was liable to be set aside for breach of the requirement of a reasonable opportunity to show cause before action under Section 27 of the Tamil Nadu Value Added Tax Act, 2006.

Analysis: The revision order was examined in the light of the common proviso to sub-sections (1) and (2) of Section 27, which mandates that no order shall be passed without giving the dealer a reasonable opportunity to show cause. The record showed that no prior notice had been issued and no opportunity had been afforded before passing the impugned order. That omission constituted a direct infraction of the statutory safeguard and vitiated the order, without any adjudication on the merits of the revision.

Conclusion: The impugned order was set aside for breach of the statutory requirement of giving a reasonable opportunity to show cause, and the matter was directed to be considered afresh after such opportunity.

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