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TMI Blog2021 (11) TMI 944X X X X Extracts X X X X X X X X Extracts X X X X ..... he eight main writ petitions and Mr.S.R.A.Ramachandran, learned Additional Government Pleader on behalf of both the respondents in all the eight writ petitions are before me. 3. Learned Revenue counsel has filed a counter-affidavit and completed pleadings. 4. Short facts shorn of elaboration will suffice as the entire matters turn on a very narrow compass. In other words, it is not necessary to delve into granular particulars qua factual matrix. 5. Suffice to say in all the eight captioned writ petitions eight different revisional orders made under Section 27 of 'the Tamil Nadu Value Added Tax Act, 2006, (Tamil Nadu Act No.32 of 2006)' [hereinafter 'TNVAT' for the sake of convenience and clarity] had been called in questi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the replies of the writ petitioner-dealer to the pre-revision notices. 9. Therefore, the captioned writ petitions are dealt with on the aforesaid short point and I interfere with the impugned orders on this one short point. In other words, all questions are left open to be canvassed before the first respondent. 10. Before I set out the operative portion of this order, I deem it appropriate to mention that for a revision legal drill under Section 27 of TNVAT Act, it is statutorily imperative to give a reasonable opportunity to the dealer to show cause. This is ingrained in the common proviso to Sub-sections (1) and (2) of Section 27 of TNVAT Act which reads as follows: 'Section 27. Assessment of escaped turnover and wrong availment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is, for ease of reference and highlighting) 11. That there is a statutory requirement is to give a reasonable opportunity to show cause and that the opportunity has been so given means the response of the dealer has to necessarily be considered while making a revisional order. It may or it may not have been considered by the first respondent but the impugned orders do not say anything about the objections. In other words, there is nothing in the impugned orders to demonstrate that the replies have been considered much less have they been dealt with. In the light of the discussions, narrative and dispositive reasoning thus far, the following order is made: (a) All the eight impugned orders i.e., orders all dated 20.03.2017 bearing referen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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