TaxTMI 
TaxTMI 
2019 (1) TMI 161
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....the cases are similar in nature, they are disposed of by way of this common order. 3. The petitioner before this Court is a dealer in fabrics and garments and an assessee on the file of the respondent herein. The subject assessment years are 2011-12 to 2013-14, for which, the petitioner filed their returns, on time and they were deemed to have been assessed in view of Section 22(2) of the TNVAT Act. However, on the basis of the inspection report and further scrutiny of web reports, the authorities found some mismatch between the Annexure I and Annexure II of seller and buyer end returns. Pursuant to the same, the respondent has issued pre-revision notice for the subject assessment years on 25.01.2018, but, the web report and other particul....
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....iting objections and the petitioner has also responded by way of reply dated 12.02.2018. This Court has perused the said pre-revision notices dated 25.01.2018. It is seen that one of the grounds raised in the pre-revision notices, as confirmed in the final impugned orders, is with regard to mismatch of particulars between Annexure I and Annexure II of seller and buyer end. But, it is seen that the show cause notice is bereft of particulars regarding the name and/or trade identification number (TIN) number of the dealer at the other hand. It is stated that cross verification of buyer and seller is made through Web. But, web report was not enclosed. Unless the intranet web report along with all details are furnished, the purchaser would not ....
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....arking upon any enquiry, even though the other end dealer is also registered within his jurisdiction. Thus, when the assessing officer has data to show that the dealers registered with him, whose returns have been accepted when compared to the other end dealer does not match, then the assessing officer is first required to enquire with the assessing officer of the other end dealer to make verifications as to whether the mismatch could have occurred due to any one of the factors, which may not be due to the deliberate default of the dealer, satisfy himself that and after such verification, if prima facie appears that the returns to be revised, at that stage, the assessing officer would be entitled to issue a show-cause notice containing full....