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Department Can't Initiate Suo-Motu Revisions Based on DCCT Letter; Appeals Must Follow JVAT Act Sections 79 & 80(1.

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....If the department was not satisfied with the original adjudication order and/or the order by which review proceeding was dropped, it was open for the department including Commissioner to direct the competent authority to prefer statutory Appeal and/or statutory Revision before the competent authority in terms of Section 79 and 80(1) of the JVAT Act. However, in our opinion, it was not open for the Revenue particularly, Additional Commissioner, Commercial Taxes to initiate suo-motu revision proceeding, that too, on the mere filing of a letter by writ petitioner-DCCT. - HC....