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    <title>2025 (7) TMI 1206 - KARNATAKA HIGH COURT</title>
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    <description>Under the Karnataka Value Added Tax Act, 2003, limitation for suo motu revision under Section 64 was treated as running from the date records were called for, not from the date of the show-cause notice, and the revision was therefore considered within time. The commentary also states that rectification under Section 69 is a distinct remedy from appeal against reassessment under Section 39(1); a taxpayer who did not appeal the reassessment could not use an appeal from rejection of rectification to challenge the reassessment order itself. The merger argument was rejected, and the appellate authority was held unable to examine the reassessment order in such proceedings.</description>
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      <link>https://www.taxtmi.com/caselaws?id=775138</link>
      <description>Under the Karnataka Value Added Tax Act, 2003, limitation for suo motu revision under Section 64 was treated as running from the date records were called for, not from the date of the show-cause notice, and the revision was therefore considered within time. The commentary also states that rectification under Section 69 is a distinct remedy from appeal against reassessment under Section 39(1); a taxpayer who did not appeal the reassessment could not use an appeal from rejection of rectification to challenge the reassessment order itself. The merger argument was rejected, and the appellate authority was held unable to examine the reassessment order in such proceedings.</description>
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