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    <title>2019 (11) TMI 666 - MADRAS HIGH COURT</title>
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    <description>Revision notices under Section 27 of the TNVAT Act were held to be premature to challenge in writ jurisdiction at the notice stage, because reopening of assessment is ordinarily examined first by the Assessing Officer unless the action is clearly time-barred or based on a demonstrable change of opinion. The dealers&#039; reliance on the Section 15 exemption and their objections to proposed purchase tax under Section 12(1)(C) were treated as issues requiring first-instance assessment on facts and classification, to be placed before the Assessing Officer with supporting material. The Assessing Officer must decide the objections independently, without being controlled by third-party circulars or enforcement directions.</description>
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    <pubDate>Thu, 31 Oct 2019 00:00:00 +0530</pubDate>
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      <description>Revision notices under Section 27 of the TNVAT Act were held to be premature to challenge in writ jurisdiction at the notice stage, because reopening of assessment is ordinarily examined first by the Assessing Officer unless the action is clearly time-barred or based on a demonstrable change of opinion. The dealers&#039; reliance on the Section 15 exemption and their objections to proposed purchase tax under Section 12(1)(C) were treated as issues requiring first-instance assessment on facts and classification, to be placed before the Assessing Officer with supporting material. The Assessing Officer must decide the objections independently, without being controlled by third-party circulars or enforcement directions.</description>
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