2021 (11) TMI 169

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....ection 27 of 'Tamil Nadu Value Added Tax Act, 2006 (Tamil Nadu Act 32 of 2005) {which shall hereinafter be referred to as 'TNVAT Act' for the sake of brevity and clarity} both dated 02.08.2021 pertaining to two Assessment Years, namely 2013-14 and 2014-15 have been assailed. 3. Ms.D.S.Vipula, learned counsel for writ petitioner in both the captioned writ petitions submits that there are three grounds on which the impugned orders are being assailed and they are as follows: a) The Department had earlier issued a notice dated 19.08.2016, writ petitioner replied vide reply dated 30.09.2016 and the matter was given quietus. The writ petitioner expected that the earlier explanation will stand good for the case on hand also....

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.... fall for consideration in a challenge to impugned order in writ jurisdiction. I have no difficulty in accepting this submission. I leave it open for de novo assessment. 7. This leaves this Court with the last submission i.e., writ petitioner not responding to the notice to show-cause. As already alluded to supra, vide common proviso to sub-sections (1) and (2) of Section 27 of TNVAT Act, it is statutorily imperative to give a reasonable opportunity to show-cause before a revision order is passed under Section 27 of TNVAT Act. The respondent has no doubt complied with this requirement by issuing 06.01.2021 notices. In the case on hand, a perusal of the impugned order reveals that the matter inter alia pertains to reconciling difference i....