Rectification under Tamil Nadu VAT law is limited to apparent errors, and no hearing is needed unless assessment or penalty is enhanced.

Rectification under Section 84 of the Tamil Nadu Value Added Tax Act is limited to correcting an error apparent on the face of the record and is not a substitute for a regular assessment proceeding. An opportunity of hearing is required only when the rectification results in enhancement of assessment or penalty. As the impugned orders did not enhance either assessment or penalty, the absence of further hearing did not amount to a violation of natural justice, and the rejection of the rectification applications was upheld.

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Issues: Whether rejection of the petitioner's rectification applications under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 for the assessment years 2014-15 and 2015-16 was liable to be interfered with on the ground of violation of natural justice.

Analysis: Rectification under Section 84 is confined to correcting an error apparent on the face of the record and cannot be treated as a regular assessment proceeding. The statutory scheme requires an opportunity of hearing only where the rectification proceedings result in enhancement of assessment or penalty. Since the impugned orders did not enhance the assessment or penalty, the absence of further hearing did not vitiate the orders.

Conclusion: The challenge to the rejection of the rectification applications failed and the impugned orders were upheld.

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