Reasoned consideration of objections is mandatory in VAT revision proceedings; unaddressed replies render revisional orders unsustainable.

Revisional orders under Section 27 of the Tamil Nadu Value Added Tax Act, 2006 require a reasonable opportunity to show cause, and the dealer's objections to pre-revision notices must be considered in the decision-making process. Where the impugned orders do not refer to the replies or otherwise show that the objections were examined and dealt with, the orders are unsustainable. A counter-affidavit cannot cure the omission in the orders themselves. The revisional orders were therefore set aside for non-consideration of the dealer's objections, and the matter was directed to be reconsidered afresh.

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Issues: Whether revisional orders passed under Section 27 of the Tamil Nadu Value Added Tax Act, 2006 were sustainable when the dealer's objections to the pre-revision notices were not shown to have been considered.

Analysis: Section 27 contains an express proviso barring a revisional order unless the dealer is given a reasonable opportunity to show cause. Once such opportunity is afforded, the objections filed in response to the pre-revision notices must be considered in the decision-making process. The impugned orders contained no reference to the dealer's replies and did not demonstrate that the objections had been examined or dealt with. A counter-affidavit could not cure this omission in the orders themselves.

Conclusion: The revisional orders were set aside on the ground of non-consideration of the dealer's objections, and the matter was directed to be reconsidered afresh.

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