Rectification jurisdiction under VAT law is limited to apparent errors; delayed petitions without enhancement need no personal hearing.

Rectification under Section 84 of the Tamil Nadu Value Added Tax Act is limited to errors apparent on the face of the record and must be sought within the statutory period. A belated attempt to invoke rectification after bypassing the statutory appeal failed, as no apparent error warranting correction was shown. Where the authority did not propose enhancement or revision of the assessment, the proviso did not require personal hearing, so absence of such hearing did not invalidate the order. The rejection of the rectification petitions was therefore sustained, and the consequential auction notice and coercive recovery action were left undisturbed.

---

---

Issues: Whether the rejection of the rectification petitions filed under Section 84(1) of the Tamil Nadu Value Added Tax Act, 2006 and the consequential auction notice suffered from legal infirmity on the grounds of absence of reasons, denial of personal hearing, and delay in invoking the rectification jurisdiction.

Analysis: Section 84 of the Tamil Nadu Value Added Tax Act, 2006 permits rectification only of an error apparent on the face of the record within the statutory period. The petitioner had not pursued the statutory appeal against the assessment orders and instead invoked rectification after about five years. The authority found no error apparent warranting rectification, and the proviso to Section 84 required notice and opportunity of hearing only where the assessment or penalty was proposed to be enhanced. Since no revision of the assessment was made, absence of personal hearing did not vitiate the order. The Court also found the petitioner's conduct showed inordinate delay and a lack of merit in the challenge to the rejection order and the consequential auction notice.

Conclusion: The rejection of the rectification petitions was upheld and the challenge to the auction notice failed.

Final Conclusion: The writ petition was found to be without merit, and the consequential coercive recovery action was left undisturbed.

Ratio Decidendi: Rectification under Section 84 can be invoked only for an error apparent on the face of the record, and where no enhancement or revision of assessment is made, denial of personal hearing does not invalidate the order.

---