2020 (12) TMI 880
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.... terms of proviso to Section 22(2) of the Tamil Nadu Value Added Tax Act, 2006 (hereinafter referred to as the 'TNVAT Act' for short) accepting the turnover reported in the monthly returns filed. Thereafter, the Respondent by Notice No. TIN/33341522659/2009-10 dated 08.10.2018 informed the Petitioner that it had been noticed on verification that a turnover of Rs. 4,51,12,496/- had been claimed towards exempted sales without furnishing supporting documents which would attract tax liability at the appropriate rate and called upon the Petitioner to file his objections for the proposal with necessary documentary evidence. Aggrieved thereby, the Petitioner has filed this Writ Petition challenging the said notice dated 08.10.2018 on the ....
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....roceedings which are taken with regard to it. It cannot and does not mean a final order of assessment alone unless there is something in the context of a particular provision which compels such a meaning being attributed to it. In our judgment despite the phraseology employed in Rule 33 the principle which has been laid in other cases relating to analogous provisions in sales-tax statute must be followed as otherwise the purpose of a provision like Rule 33 can be completely defeated by taking certain collateral proceedings and obtaining a stay order as was done in the present case or by unduly delaying assessment proceedings beyond a period of three years." The aforesaid binding ruling has been followed by the Full Bench of this Court in M....
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....ss consists of various steps such as calling for the records of the proceedings, making an enquiry by the revisional authority or causing an enquiry to be made thereon, and passing final orders thereon as the revisional authority thinks fit. Therefore, the entire process commencing from the calling of the records and ending with the passing of the final order has been termed as revision in the said Section. Each one of the steps in the process is a revisional process. Therefore, if any one of the steps in the process has been initiated within the period of limitation, there is no further limitation on the exercise of the power." It is clearly evident from the dictum laid down in these authoritative pronouncements that for the purpose of re....