Madras High Court
Tvl.Pupa Lineraa vs The State Tax Officer on 27 October, 2021
W.P(MD) No.14494 of 2021
Puhpa Lineraa v. The State Tax Officer, Karur
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
DATED: 27.10.2021
CORAM
THE HON'BLE MR.JUSTICE R.SURESH KUMAR
W.P.(MD)No.14494 of 2021
and
W.M.P(MD)No.11423 of 2021
Tvl.Pupa Lineraa,
Represented by its partner,
S.Pushpa Rajan. ...Petitioner
-Vs-
The State Tax Officer,
Karur-3 Division,
Karur. ... Respondent
Prayer: Writ Petition filed under Article 226 of Constitution of India, to
issue a Writ of Certiorari, calling for the records on the files of the
respondent herein TIN:33513764575/2012-2013, dated 30.03.2021 and
to quash the same.
For Petitioner : Mr.N.Inbarajan
For Respondent : Mr.R.Suresh Kumar,
Government Advocate.
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W.P(MD) No.14494 of 2021
Puhpa Lineraa v. The State Tax Officer, Karur
ORDER
The Prayer sought for herein is for a Writ of Certiorari, to
call for the records on the file of the respondent herein TIN:
33513764575/2012-2013, dated 30.03.2021 and to quash the same.
2. The petitioner is a registered dealer on the file of the
respondent and was carrying on business of buying and selling Ceramic
tiles and processing the broken tiles and sold them as border tiles. The
petitioner claimed to have stopped the business activities including the
process of broken tiles with effect from 01.06.2016. Accordingly, the
registration granted under the Tamil Nadu Value Added Tax Act, 2006
(hereinafter referred to as the “TNVAT Act” in short) and under the
Central Sales Tax Act, 1956 were cancelled by the proceedings dated
08.06.2016.
3. Insofar as the assessment year 2012-2013, the petitioner
already filed a return and in view of Section 22(2) of the TNVAT Act,
the said return deemed to have been accepted.
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Puhpa Lineraa v. The State Tax Officer, Karur
4. While that being so, there was an inspection by the
officers of the Enforcement Wing of the respondent Department on
28.04.2015. During the inspection, the petitioner claimed to have
produced all the documents and accounts right from 2010-2011 to
2014-2015 which were verified by the inspecting authorities.
5. However, thereafter, an order has been passed on
30.09.2016, under Section 22(4) of the TNVAT Act, where on satisfying
with the documents produced by the petitioner/dealer, there has been a
NIL balance of the tax payable by the petitioner and accordingly, the said
order was passed on 30.09.2016.
6. However, now all of a sudden, the respondent has issued
a show cause cum proposal for a revision of tax for the year 2012-2013
on 22.02.2021. Pursuant to the said notice and proposal dated 22.2.2021,
the petitioner had given reply on 25.03.2021, where the petitioner had
stated that the petitioner had closed the business on 01.06.2016 itself and
the registration number under TNVAT Act itself was cancelled. Hence,
the petitioner requested to drop further proceedings pursuant to the
notice, dated 22.02.2021.
7. However, the respondent, without taking into account of
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Puhpa Lineraa v. The State Tax Officer, Karur
the said request made by the petitioner or by rejecting the said contention
of the petitioner/dealer, has issued the impugned revised assessment
order under Section 27 of the TNVAT Act on 30.03.2021, which is now
been challenged by the petitioner in the present writ proceedings.
8. Assailing the said impugned order, dated 30.03.2021,
among various other grounds on merits of the case, as a preliminary
ground, Mr.N.Inbarajan, learned counsel appearing for the petitioner has
raised a point that the impugned revised assessment under Section 27 of
the TNVAT Act, is barred by limitation.
9. In this context, the learned counsel relied upon Section 27
(1)(a) of the TNVAT Act, which reads thus:
“Section 27. Assessment of escaped turnover and
wrong availment of input tax credit.-(1)(a) Where, for any
reason, the whole or any part of the turnover of business of
a dealer has escaped assessment to tax, the assessing
authority may, subject to the provisions of sub-section(3),
at any time within a period of (six years from the date of
assessment), determine to the best of its judgment the
turnover which has escaped assessment and assess the tax
payable on such turnover after making such enquiry as it
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Puhpa Lineraa v. The State Tax Officer, Karur
may consider necessary.”
10. Therefore, as per the said provision, if at all any revised
assessment to be made for the alleged escaped turnover or wrong
availment of ITC i.e., Input Tax Credit, within six years period from the
date of assessment, it should be determined to the best of its judgment,
the turnover which has escaped assessment and the tax can be assessed.
11. By relying upon this provision, the learned counsel
would further contend that, insofar as the six years limitation is
concerned, which would start from 31st October 2013, the reason being
that, the assessment relates to assessment year 2012-2013. Therefore, for
the said assessment year, the return had been filed by the petitioner and
by virtue of the deeming provision available under Sub-Section 2 of
Section 22 of the TNVAT Act, by 31 st October of the succeeding year,
every dealer shall be deemed to have been assessed provided if the
returns are in the prescribed form and accompanied with the prescribed
documents and proof of payment of tax.
12. Therefore, the learned counsel would contend that in this
case, since it is assessment year 2012-2013, as per the deeming provision
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Puhpa Lineraa v. The State Tax Officer, Karur
under Section 22(2) of the TNVAT Act, by 31st October 2013, the
petitioner deemed to have been assessed. Therefore, the assessment was
over insofar as the petitioner is concerned for the said assessment year.
Hence, according to the petitioner's counsel, the limitation as prescribed
under Section 27 (1) (a) of the TNVAT Act would commence from 1st
November 2013. In that case, the six years limitation period would be
over by 31st October 2019, whereas in the present case by invoking
Section 27 of the TNVAT Act, the respondent issued notice on
22.02.2021. Therefore, it is certainly beyond the limitation of six years.
Hence, on that ground alone the invocation of Section 27 of the TNVAT
Act which culminated in the impugned order is vitiated. Therefore, the
learned counsel appearing for the petitioner seeks indulgence of this
Court against the impugned revised assessment.
13. Per contra, Mr.R.Sureshkumar, learned Government
Advocate appearing for the respondent would contend that, under Sub-
Section 4-A of Section 2 of the TNVAT Act, which has been amended or
inserted subsequently, the word “assessment” has been defined that,
"assessment" means an assessment made or deemed to have been made
under this Act and includes a re-assessment or revision of assessment.
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Puhpa Lineraa v. The State Tax Officer, Karur
14. By relying upon this definition clause, the learned
Government Advocate would contend that, the assessment within the
meaning of Section 2 (4-A) is concerned, it is not confined only with the
assessment made under Section 22(2) of the TNVAT Act by way of even
the deemed assessment but also includes the re-assessment made under
Section 22(4) of the TNVAT Act.
15. In this context, the learned Government Advocate would
further contend that, insofar as the petitioner's case is concerned, such a
re-assessment has been made on 30.09.2016. Therefore, if at all the
limitation for invoking Section 27 of TNVAT Act to start, it should be
started only from the said date i.e., 30.09.2016. In that case, the notice
issued under Section 27(1) of the TNVAT Act, dated 22.02.2021, is
saved by the limitation and therefore, the said ground raised by the
petitioner's counsel cannot be countenanced, he contended.
16. In support of his contention, learned Government
Advocate has relied upon two decisions of the Hon'ble Supreme Court.
The first decision is (1977) 1 SCC 703 in the matter of Deputy
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Puhpa Lineraa v. The State Tax Officer, Karur
Commissioner of Commercial Taxes Vs. H.R. Sri Ramulu. He relied
upon the following observations made by the Hon'ble Supreme Court in
this context:
“7.The short question which arises for
determination in these appeals is that in the event of an order
having been made under section 12-A of the Act, what is the
starting point for computing the period of four years, mentioned
in section 21 (3), for the exercise of the powers under section
21(2). Is it the initial assessment order or is if the order made
under section 12A ? In the context of the present case, the
question to be answered is as to whether the period of four years
is to be calculated from March 21, 1963 when the initial
assessment orders were made, or from June 8, 1966 when the
orders under section 12-A of the Act were made. So far as this
question is concerned, we are of the opinion that the period of
four years should be calculated from June 8, 1966, i.e., the date
on which orders under Section 12-A of the Act were made. The
reason for that is that once an assessment is reopened, the initial
order for assessment ceases to be operative. The effect of
reopening the assessment is to vacate or set aside the initial
order for assessment and to substitute in its place the order
made on reassessment. The initial order for reassessment cannot
be said to survive, even partially, although the justification for
reassessment arises because of turnover escaping assessment in
a limited field or only with respect to a part of the matter
covered by the initial assessment order. The result of reopening
the assessment is that a fresh order for reassessment would have
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Puhpa Lineraa v. The State Tax Officer, Karur
to be made including for those matters in respect of which there
is no allegation of the turnover escaping assessment. As it is, we
find that in the present case the assessment orders made under
section 12-A were comprehensive orders and were not confined
merely to matters which had escaped assessment earlier. In the
circumstances, the only orders which could be the subject-
matter of revision by the appellant were the orders made under
section 12-A of the Act and not the initial assessment orders.
8.In the case of J. Jagannathan Rao Vs. CIT and
Excess Profits Tax, Andhra Pradesh this Court dealt with
section 34 of the Indian Income- tax Act, 1922 which relates to
reassessment in the case of income escaping assessment. It was
held by this Court that once assessment is reopened, the
previous underassessment is set aside and the whole
proceedings star afresh. Ramaswami, J. speaking for the Court
observed:
"Section 34 in terms states that once the Income-
tax Officer decides to reopen the assessment he could do so
within the period prescribed by serving on the person liable to
pay tax a notice containing all or any of the requirements which
may be included in a notice under section 22(2) and may
proceed to assess or reassess such income, profits or gains. It is,
therefore, manifest that once assessment is reopened by issuing
a notice under sub-section (2) of section 22 the previous
underassessment is set aside and the whole assessment
proceedings start afresh. When once valid proceedings are
started under section 34(1)(b) the Income tax Officer had not
only the jurisdiction but it was his duty to levy tax on the entire
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Puhpa Lineraa v. The State Tax Officer, Karur
income that had escaped assessment during that year."
9.In the case of Commissioner of Sales Tax, Madhya
Pradesh v. H.M. Esufali H.M. Abdulali this Court dealt with
reassessment made under section 19 of the Madhya Pradesh
General Sales Tax Act, 1958. It was held that when
reassessment is made, the former assessment is completely
reopened and in its place fresh assessment is made. Hegde, J.
speaking for the Court observed:
"What is true of the assessment must also be true
of reassessment because reassessment is nothing but a fresh
assessment. When reassessment is made under section 19, the
former assessment is completely reopened and in its place fresh
assessment is made. While reassessing a dealer, the assessing
authority does not merely assess him on the escaped turnover
but it assesses him on his total estimated turnover. While making
assessment under section 19, if the assessing authority has no
power to make best judgment assessment, all that the assessee
need do to escape reassessment is to refuse to file a return or
refuse to produce his account books. If contention taken on
behalf of the assessee is correct, the assessee can escape his
liability to be reassessed by adopting an obstructive attitude. It
is difficult to conceive that such could be the position in law."
10.In International Cotton Corpn. (P) Ltd. v. Commercial
Tax Officer, HubIi, this Court held that once an assessment
order had been rectified and it was sought to make a further
rectification of that order, the period of limitation for making
such further rectification would commence not from the date of
the original assessment order but from the date of the earlier
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Puhpa Lineraa v. The State Tax Officer, Karur
rectification order. Alagiriswami, J. speaking for the Court in
this context observed:
"The other attack that the rectification order is
beyond the point of time provided in Rule 38 of the Mysore Sales
Tax Rules is also without substance. What was sought to be
rectified was the assessment order rectified as a consequence of
this Court's decision in Yaddalam's case. After such rectification
the original assessment order was no longer in force and that
was not the order sought to be rectified. It is admitted that all
the rectification orders would be within time calculated from the
original rectification order. Rule 38 itself speaks of 'any order'
and there is no doubt that the rectified order is also 'any order'
which can be rectified under Rule 38."
Although the above case related to an order which had
been subsequently rectified, the principle laid down therein
would, in our opinion, be also applicable in cases where
reassessment is made on the ground that certain amounts of
turnover had escaped assessment.”
17. Similarly, he also relied upon yet another decision of the
Hon'ble Supreme Court reported in (1987) 1 SCC 684 in the matter of
Kundan Lal Srikishan, Mathura (U.P) Vs. Commissioner of Sales Tax,
U.P., where it has been held that, on re-assessment or rectification,
period of limitation would run from the date of such order and not from
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the date of the original assessment order. By relying upon these two
decisions, the learned Government Advocate would content that the law
laid down by the Hon'ble Supreme Court in the said two cases cited
supra would strengthen the argument of him that if the limitation point
can be raised, it shall start only from the re-assessment that has been
made only in the year 2019 and not from the original deemed assessment
from 31.10.2013. Therefore the learned counsel would contend that the
impugned proceedings which culminated in the revised assessment order
under Section 27 of the TNVAT Act is to be sustained.
18. I have considered the rival submissions made by the
learned Counsel appearing for both the parties and have perused the
materials placed before this Court.
19. It is the contention of the learned counsel appearing for
the petitioner that once there is a deeming provision available under
Section 22 (2) of the TNVAT Act which in fact has been brought in by
way of amendment with effect from 19.06.2012 by Act No.23 of 2012,
on completion of the 31st day of October of the succeeding year, there
shall be a deemed assessment and once deemed assessment is over, the
question of re-assessment does not arise. Hence, even within the
meaning of sub-Section (4-A) of Section 2 of the TNVAT Act, for all
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practical purposes, especially for the purpose of calculating the
limitation, the word “assessment” would denote only the assessment
made under Section 22 (2).
20. The learned counsel would further contend that, if at all
no notice was issued within the period before 31st October of the
succeeding year on any return filed by the assessee like the
petitioner/dealer, in that case what shall be the final order to be passed
under Section 22(2) or 22 (4), then it can be stated that such final
assessment can be treated as an assessment for the purpose of calculating
the limitation to invoke Section 27 of the TNVAT Act.
21. If we develops the said argument made by the learned
Counsel appearing for the petitioner, this Court, on having a close
reading of the provisions, namely, Section 22 (2) and 22(4), is of the
view that, after the amendment, Section 22(2) reads thus:
“The assessing authority shall accept the returns
submitted for the year, by the dealer, if the returns are in the
prescribed form and accompanied with the prescribed
documents and proof of payment of tax. Every such dealer
shall be deemed to have been assessed for the year on the 31st
day of October of the succeeding year..”
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Puhpa Lineraa v. The State Tax Officer, Karur
22. While making amendment of Sub- Section 2 of Section
22 of the TNVAT Act, the following reasons have been given by the
Legislature as Statement of Objects and Reasons, where it has been
stated that, in the Value Added Tax Acts of many other States, such a
requirement of passing an assessment order is not found, and instead,
deemed assessment on filing of returns by the dealers is being followed,
so that, at any time, within the period of limitation, without loss of time,
the escaped revenue is assessed by way of revision. It is further stated in
the Statement of Objects and Reasons by the Legislature that, in tune
with the general principles of the Value Added Tax and the provisions
contained in the Value Added Tax Acts of other States, the Government
have decided to dispense with the existing procedure of passing an
assessment order by the assessing authority and to replace it with a
system of deemed assessment. Under the proposed system of deemed
assessment, a dealer shall be deemed to have been assessed if the returns
are filed as prescribed.
23. If we take up the said Objects and Reasons given for
such amendment into aid, the intention of Legislature to make an
amendment of Section 22 (2) of the TNVAT Act is to close the chapter
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Puhpa Lineraa v. The State Tax Officer, Karur
by giving a deeming provision and once the dealer filed return in the
prescribed form and accompanied with the prescribed documents and
proof of payment of tax, every such dealer shall be deemed to have been
assessed for the year on the 31st day of October of the succeeding year.
24. Here in the case in hand, admittedly, return has been
filed by the petitioner/dealer on and before 31st October 2013, since it is a
succeeding year for the assessment year 2012-2013. Since, no notice has
been issued on the alleged reason that the return has not been filed in the
prescribed form by the petitioner/dealer and 31st day of October 2013,
also passed, on such date, the deeming provision has to be given effect to
and accordingly, the petitioner has to be treated as deemed assessee for
the year 2012-2013.
25. Once the dealer is assessed under the deeming provision
and under Sub Section 2 of Section 22 of the TNVAT Act, then, whether
there can be any scope for the Assessing Authority to once again reassess
it by invoking the Sub Section 4 of Section 22 of the TNVAT Act itself
is a question.
26. In this context, even though such an attempt has been
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Puhpa Lineraa v. The State Tax Officer, Karur
made in respect of the petitioner some time in 2019 where a Nil tax due
has been made by order dated 30.09.2016, on further close reading of
Section 22(4) of the TNVAT Act, this Court is of the view that, once the
dealer is deemed to have been assessed for a particular assessment year
on completion of the 31st October of the succeeding year, it means that,
the assessment has been made with all respects including the return are
filed in prescribed form and accompanied with the prescribed documents
and proof of payment of tax.
27. Therefore, for the very same reasons under Sub Section
4 of Section 22 of the TNVAT Act, the assessing authority cannot reopen
it saying that the dealer to the best of its judgment can be once again
assessed.
28. Moreover, insofar as Section 27 (1) (a) is concerned, the
reasons for revising assessment is something different than of the re-
assessment as contemplated under Section 22(4) of the TNVAT Act.
29. In Section 27 (1) (a) if the dealer has escaped assessment
to tax, the Assessing Authority may at any time within a period of six
years from the date of assessment determine to the best of its judgment
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Puhpa Lineraa v. The State Tax Officer, Karur
the turnover which has escaped assessment and assess the tax payable on
such turnover after making such enquiry. In such circumstances, Section
27 of the revised assessment is a different proceedings than the one of
section 22(4) of the TNVAT Act. Section 22(4) proceedings if at all to be
made, it can be made only within the limitation i.e., within the period
before the deeming clause come into effect i.e., on or before 31st day of
October of the succeeding year. Otherwise, if we construed this provision
in different manner to state that after the 31st day of October of the
succeeding year, once the deeming assessment is made, then it is open to
the Assessing Officer to invoke Section 22(4), then the ingredients made
in Section 22(4) may not be available to the Assessing Officer, because
the words "the return filed is incomplete or incorrect or if not
accompanied with any of the document prescribed or proof of payment of
tax", cannot once again be restated, since the deeming assessment once
comes into effect and accepted it is presumed that such deeming
assessment has been made or accepted only after accepting the return
submitted by the dealer accompanied with the prescribed documents and
proof of payment of tax.
30. Therefore, once the deeming assessment is made, that
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Puhpa Lineraa v. The State Tax Officer, Karur
can be treated as an assessment, but before the deeming assessment is
made or accepted, Section 22(4) of the TNVAT Act can very well be
invoked and in that case the dealer can be assessed to the best of its
judgment by the Assessing Officer and if anything is done under Section
22(4) of the TNVAT Act before 31st October of the succeeding year of
the concerned assessment year, then the re-assessment order or the
assessment order made under Section 22(4) of the TNVAT Act can be
treated as assessment within the meaning of Section 2 (4-A) of the
TNVAT Act and the limitation of six years under Section 27 (1) (a) of
the TNVAT Act can also start from that assessment.
31. However, here in the case in hand, there has been a
deemed assessment for the assessment year 2012-2013. Insofar as the
petitioner/ dealer which was over by the 31st October 2013.
32. Thereafter, if at all any revision has to be made on the
alleged reason of escaped turnover by invoking Section 27 (1) (a) of the
Act, such action can be initiated by the Assessing Officer by way of
revised assessment to issue a show-cause notice, but strictly following
the six years limitation period, which would start from the original
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deeming assessment date i.e., 31st October of the succeeding year.
33. In this Context, the original deeming assessment for the
assessment year 2012-2013 of the dealer i.e., the petitioner is 31 st
October 2013, from that date if we calculate the limitation of six years as
contemplated under Section 27 (1) (a) of the TNVAT Act that ends by
31st October 2019, whereas the notice under Section 27 (1) (a) of the
TNVAT Act was issued only on 22.02.2021. Therefore, certainly it is
beyond the limitation of six years.
34. In this context, even though an attempt has been made
by the learned Government Advocate appearing for the
respondent/revenue by citing the afore cited two decisions of the Hon'ble
Supreme Court, this Court feels that, the two decisions may not apply to
the present facts of the case for the reason that (1977) 1 SCC 703 (cited
supra) decision arising out of the Mysore Sales Tax Act, 1957 and (1987)
1 SCC 684 (cited supra) decision arose out of U.P.Sales Tax Act, 1948.
35. In these two cases, such kind of deeming provisions as
that of under Section 22 (2) of the TNVAT Act either was not available
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Puhpa Lineraa v. The State Tax Officer, Karur
or has not been dealt with.
36. No doubt, if there is no deeming provision as available
under Section 22(2) of the TNVAT Act which we have discussed herein
above, certainly what was the last assessment made by the revenue would
be taken into account for the purpose of calculating the limitation for
invoking the revised assessment under Section 27 of the TNVAT Act.
37. This position would have been possible prior to the
amendment made in the year 2012 under which the deeming provision
has been inserted in Sub-Section 2 of Section 22 of the TNVAT Act.
38. Once a deeming provision comes into effect, for every
assessment year, 31st October of the succeeding year is to be taken as a
date where deeming provision comes into effect and every such return
filed by the assessee within the time should be treated as a deemed
assessment.
39. But, before the expiry of the deeming assessment period,
the revenue wanted to invoke the best judgment theory by invoking
Section 22(4) of the TNVAT Act that would be possible for the revenue.
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However, once the deeming assessment is completed at the end of 31 st
October of the succeeding year, then that date shall be construed as an
assessment date for the purpose of taking the limitation of six years for
invoking the proceedings of revised assessment under Section 27 (1) (a)
of the TNVAT Act.
40. In that view of the matter, this Court feels that there is
every force in the said contention raised by the learned counsel appearing
for the petitioner. However, the submission made by the learned
Government Advocate may not hold good because of the reasons stated
hereinabove. Hence, this Court is of the considered view that the
impugned assessment order, which in fact started with a show-cause
notice, dated 22.02.2021, since was issued beyond the six years
limitation period as prescribed under Section 27 (1) (a) of the TNVAT
Act, is unsustainable.
41. In these circumstances, this Court has no hesitation to
hold that the impugned assessment order is unsustainable and
accordingly it is liable to be interfered with. Hence the impugned order
is set aside and the Writ Petition is allowed. However, there will be no
order as to costs. Consequently, the connected Miscellaneous Petition is
also closed.
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W.P(MD) No.14494 of 2021
Puhpa Lineraa v. The State Tax Officer, Karur
27.10.2021
Index : Yes
lr/vsm
Note:
In view of the present lock down owing to COVID-19
pandemic, a web copy of the order may be utilized for
official purposes, but, ensuring that the copy of the order
that is presented is the correct copy, shall be the
responsibility of the Advocate/litigant concerned.
To
The State Tax Officer,
Karur-3 Division,
Karur.
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W.P(MD) No.14494 of 2021
Puhpa Lineraa v. The State Tax Officer, Karur
R.SURESH KUMAR, J.
lr/vsm
Order made in
W.P.(MD)No.14494 of 2021
and
W.M.P(MD)No.11423 of 2021
Dated:
27.10.2021
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W.P(MD) No.14494 of 2021
Puhpa Lineraa v. The State Tax Officer, Karur
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