Post-assessment declaration forms may be considered through rectification, while natural justice challenge to assessment was rejected.

Natural justice was not established as a ground to interfere with the assessment orders because the record did not show denial of a fair hearing, and delay in receiving notice was not followed by any immediate intimation explaining non-appearance. The dealer was nonetheless entitled to seek consideration of C and F declaration forms after assessment, because post-assessment declaration material cannot be rejected merely for late production and may be examined through rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006, read with the corresponding corrective power under sales tax law. The assessment orders were left intact, but rectification proceedings were permitted and coercive action was kept in abeyance.

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Issues: (i) Whether the impugned assessment orders called for interference on the ground of violation of principles of natural justice; (ii) Whether the dealer could seek consideration of the C and F declaration forms through rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006.

Issue (i): Whether the impugned assessment orders called for interference on the ground of violation of principles of natural justice.

Analysis: The record showed that the petitioner did not establish a sufficient basis to hold that the respondent had denied a fair hearing before passing the assessment orders. The Court also noted that, even assuming delay in receipt of the hearing notice, no immediate intimation was sent to explain non-appearance. On that footing, the plea of violation of natural justice was not accepted in relation to the assessment orders as they stood on the date of their passing.

Conclusion: The challenge to the assessment orders on the ground of violation of natural justice was rejected.

Issue (ii): Whether the dealer could seek consideration of the C and F declaration forms through rectification under Section 84 of the Tamil Nadu Value Added Tax Act, 2006.

Analysis: The Court followed the settled position that declaration forms produced after completion of assessment cannot be refused merely for that reason, and that the assessing authority has power to entertain such material through rectification or allied corrective powers. Reliance was placed on the legal position recognised in earlier decisions and on the statutory framework under Section 84 of the Tamil Nadu Value Added Tax Act, 2006, read with the analogous power under Section 55 of the Tamil Nadu General Sales Tax Act, 1959. The petitioner was therefore required to resubmit the forms and seek rectification in the prescribed manner.

Conclusion: The petitioner was entitled to pursue rectification based on the C and F declaration forms, and the respondent was directed to consider the application in accordance with law.

Final Conclusion: The assessment orders were not quashed, but the petitioner was given a limited post-assessment remedy to seek rectification with supporting declaration forms, and coercive action was kept in abeyance until that exercise was completed.

Ratio Decidendi: An assessing authority cannot refuse to consider C and F declaration forms merely because they are produced after assessment, and such post-assessment material may be examined through the statutory power of rectification where the governing law so permits.

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