Rectification cannot reopen a final VAT assessment when the statutory appeal was not filed in time.

Rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 is confined to mistakes apparent on the face of the record and cannot be used to reopen the substantive basis of a completed assessment. Where the assessment has attained finality, a rectification request that in substance seeks to bypass the statutory appellate remedy is not maintainable. The Madras High Court found no apparent error justifying exercise of rectification power and noted that the assessee had not challenged the assessment before the Appellate Commissioner within time. The rejection of the rectification request was therefore upheld.

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Issues: Whether the rejection of the rectification request under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 was justified when the challenge was directed against a completed assessment and the petitioner had not pursued the statutory appeal in time.

Analysis: The rectification jurisdiction is confined to mistakes apparent on the face of the record and does not extend to reopening the substantive basis of an assessment. The assessment had attained finality, and the grievance raised through rectification was in substance an attempt to bypass the appellate remedy. The Court also found no error apparent warranting invocation of the rectification power and noted that the petitioner had failed to challenge the assessment before the Appellate Commissioner within time.

Conclusion: The rejection of the rectification request was upheld and the challenge failed.

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