TMI Blog2021 (11) TMI 827X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 27 of the TNVAT Act, 2006 from the aforesaid date. The arguments advanced by the learned counsel for the petitioner is acceptable in view of the fact that no other proceedings were pending at the instance of the petitioner so as to exclude the time under terms of Section 27(6), 27(7) and 27(8) of TNVAT Act, 2006. The impugned notices are to be declared as time barred and therefore liable to be quashed and are accordingly quashed subject to the rider that the petitioner had filed a complete return for the respective year along with the declaration and document for completing the assessment to invoke Section 27 of the TNVAT Act, 2006 - Petition allowed. - W.P.Nos.3028, 3030 & 3031 of 2019 - - - Dated:- 9-11-2021 - Honourable ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erence has been made to Paragraph 14 from the aforesaid instruction, which reads as under:- 14. In fine, all the Joint Commissioners, are instructed that excepting the above circumstances specified in the para 13.1(A) to (F), wherever, time limit prescribed under the Act for the purpose of Assessment in all the cases is barred by limitation, no further action in the form of issue of notices, summons need to be taken in all the cases sent through random selection process vide reference 6th cited. Further, wherever notices have already been issued in the cases barred by limitation, said Notices have to be withdrawn immediately as it would amount to causing hardship and harassment to Tax Payers. 5. The learned counsel for the petitio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e amendment to Section 22(2) of the TNVAT Act, 2006 in the year 2012, if no Assessment Orders were passed for the Assessment Years 2006-2007 to 2010-2011, assessment is deemed to have been completed on 30.06.2012. Since the assessment is deemed to have been completed on 30.06.2012, the avenue to revise the assessment is only under Section 27 of the TNVAT Act, 2006 from the aforesaid date. Section 27(7) of the TNVAT Act, 2006 excludes certain period reads as under:- Section 27.Assessment of escaped turnover and wrong availment of input tax credit:- (7). In computing the period of limitation for assessment or re-assessment under this section, the time during which any appeal or other proceeding in respect of any other assessment or re- ..... X X X X Extracts X X X X X X X X Extracts X X X X
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