Threshold interference with revisional show-cause notices is exceptional unless the notice is wholly without jurisdiction or non est.

Revisional show-cause notices invoking section 32(1) of the Telangana VAT Act were not liable to be quashed at the threshold because they were tentative and within the revisional authority's competence. The petitioners could raise objections in reply, including reliance on Supreme Court precedent and State circulars, before the authority itself. Interference at the notice stage is exceptional and is warranted only where the notice is wholly without jurisdiction or otherwise non est. As the notices were neither sketchy nor cryptic and no lack of competence was shown, the writ challenge failed and the petitioners were left to pursue their objections in accordance with law.

---

---

Issues: Whether the revisional show-cause notices under Section 32(1) of the Telangana Value Added Tax Act, 2005 were liable to be interfered with at the threshold.

Analysis: Section 32(1) empowers the revisional authority to call for the record and to revise, modify or set aside an order if it is prejudicial to the interests of revenue. The challenge was not based on lack of competence. The notices were only tentative in nature, and the petitioners could raise all objections, including distinction of the Supreme Court decision relied upon in the notices and reliance on State circulars, in their replies. The settled principle is that interference at the show-cause notice stage is exceptional and is not warranted unless the notice is wholly without jurisdiction or otherwise non est. The notices here were neither sketchy nor cryptic in the sense that would justify interference.

Conclusion: The revisional show-cause notices were not liable to be interfered with and the challenge failed.

Final Conclusion: The writ petitions were disposed of, leaving the petitioners to pursue their objections before the revisional authority in accordance with law.

Ratio Decidendi: A tentative show-cause notice invoking revisional power will not be quashed at the threshold unless it is shown to be wholly without jurisdiction or otherwise non est; objections on merits and on prejudice to revenue are to be raised before the issuing authority.

---