{"id":210397,"date":"2008-06-18T00:00:00","date_gmt":"2008-06-17T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/sanat-product-limited-vs-deputy-commercial-tax-officer-on-18-june-2008"},"modified":"2018-05-24T20:44:54","modified_gmt":"2018-05-24T15:14:54","slug":"sanat-product-limited-vs-deputy-commercial-tax-officer-on-18-june-2008","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/sanat-product-limited-vs-deputy-commercial-tax-officer-on-18-june-2008","title":{"rendered":"Sanat Product Limited vs Deputy Commercial Tax Officer on 18 June, 2008"},"content":{"rendered":"
Madras High Court<\/div>\n
Sanat Product Limited vs Deputy Commercial Tax Officer on 18 June, 2008<\/div>\n
       \n\n  \n\n  \n\n \n \n BEFORE THE MADURAI BENCH OF THE MADRAS HIGH COURT\n\nDATED: 18\/06\/2008\n\nCORAM\nTHE HONOURABLE MR.JUSTICE P.JYOTHIMANI\n\nW.P.(MD)No.2728 of 2008\nand\nM.P.(MD).No.1 of 2008\n\nSanat Product Limited,\nRam Nagar,\nK.Rajadhani Kotai\nKodai road,\nDindigul.\t\t\t\t    .. Petitioner\n\nVs.\t\n\nDeputy Commercial Tax Officer,\nNilakottai\nDindigul District.\t\t\t    .. Respondent\n\n      \t\t\t\t\t\t\nPRAYER\n\nWrit Petition filed under Article 226 of the Constitution of India,\npraying for the issuance of a Writ of Certiorari, to call for the records in\nTNGST No.5300726\/2005-06 dated 25.02.2008 on the file of the Deputy Commercial\nTax Officer, Nilakottai and quash the same as illegal, arbitrary, without\njurisdiction and against the law.\n\n!For Petitioner ...Mr.A.Thiyagarajan, Senior\n  \t\t   counsel for Mr.S.Karunahar\n\t\t\n^For Respondent ...Mr.V.Rajasekaran, Special\n\t\t    Government Pleader\n\n:ORDER\n<\/pre>\n
\tThe Writ petition is directed against the order of revision of assessment
\npassed by the respondent under Section 16(1)(a) of the Tamil Nadu General Sales
\nTax Act.\n<\/p>\n
\t2. The short facts leading to the passing of the said impugned revision of
\nassessment order as follows:\n<\/p>\n
\t(i) The petitioner has submitted accounts for the assessment year 2005-06
\nwith the amount of taxable turnover which was accepted by the respondent as
\nassessing authority by an order dated 05.03.2007,who passed orders on the basis
\nof entries in the books of accounts and after verifying the same.  However, on
\n15.03.2007, a revision notice was issued for proposing to levy tax at the rate
\nof 12.6% under Section 7A (1)(c) on the turnover of Rs.1,55,93,290\/-, stating
\nthat the turmeric purchased by the petitioner locally has been despatched to
\noutside the state as a branch transfer and therefore has not suffered sales tax
\nwithin the State of Tamil Nadu.\n<\/p>\n
\t(ii) The respondent sought to revise the assessment proposing to re-
\ndetermine the total and taxable turnover at Rs.1,72,61,077\/-.  In addition to
\nthat, the respondent has also proposed to levy  penalty under Section 16(2) of
\nTNGST Act.\n<\/p>\n
\t(iii) The petitioner has filed his various objections on 21.02.2008
\nincluding that the proposal of the levy of tax is without jurisdiction and the
\nproposed levy of 12.6% is without reference to any entry in the schedule, that
\nthe turmeric is exempted from tax under item No.81 of III schedule, that the
\nturnover did not cross 300 crores in the year, that to attract Sections 3 & 4,
\nthe goods must have been purchased against the form XVII, that the turnover was
\nreported and verified by the respondent at the time of original assessment and
\nthere was no escapement of turnover, that for the reported turnover no penalty
\ncan be levied, as the same was not an escaped turnover and that branch transfer
\nis not a sale attracting sales tax.\n<\/p>\n
\t(iv) The complaint of the petitioner is that by the impugned revised
\nassessment order dated 25.05.2008,  while rejecting the objections of the
\npetitioner, the respondent has levied tax of Rs.19,64,755\/-, surcharge of
\nRs.98,238 and a penalty of Rs.30,94,490\/-.  The case of the petitioner is that
\neven though, an appeal lies against the said order under Section 31 of the TNGST
\nAct, the Writ Petition is filed challenging the revised assessment order on the
\nground that the same is patently illegal and without jurisdiction and against
\nthe law.\n<\/p>\n
\t(v) Further, it is the case of the petitioner as contended by the learned
\nsenior counsel that there is no escaped turnover as during the original
\nassessment itself the turnover has been correctly informed.  It is the further
\ncase of the petitioner that the original assessment order was passed by the
\nrespondent based on the books of entries and after verification of the entire
\nrecords and therefore, there was no suppression and in such circumstances
\nquestion of payment of penalty does not arise.  It is also the further case that
\nthere is no provision for levy of tax for turmeric at 12.6% and the same is
\nwithout reference to any law and without jurisdiction.  It is the further case
\nof the petitioner as contended by Mr.A.Thiyagarajan, the learned senior counsel
\nfor the petitioner that the petitioner has in fact disclosed the total taxable
\nturnover and also submitted the relevant branch transfer challans.  That apart,
\nthe branch transfer is not a sale within the meaning of sale under the provision
\nof TNGST Act.  Further the respondent’s total turnover does not exceed Rs.300
\ncrores and therefore, the levy of tax is illegal and liable to be set aside.\n<\/p>\n
\t3. The respondent in counter affidavit has stated that the Writ Petition
\nis not maintainable for the reason that there is an alternative remedy of appeal
\nbefore the Appellate Assistant Commissioner available as per Section 31 of the
\nTNGST Act.  Further, the revision made by the respondent is well within the
\npower under Section 16 of the TNGST Act.  It is also stated that turmeric is
\nexempted as per item 16 of Part B of III schedule which reads as chillies,
\ntamarind, coriander, turmeric and shikakai sold by any dealer whose total
\nturnover in respect of the said items does not exceed Rs.300 crores in a year.\n<\/p>\n
\t4. According to the respondent, the said provision does not mean that
\nthere is a general exemption  and the same is conditional.  It is also further
\nstated that even when the goods are despatched outside the State other than by
\nway of sale is liable to be assessed for tax under Section 7(A)(1)(c) of the
\nTNGST Act 1959.  The respondent would rely upon the order of the Tribunal
\nreported in (2005)139 STC 294(TNTST).  It is further stated that turmeric being
\nnot enumerated specifically in the Ist schedule of TNGST Act, it falls under the
\nresiduary entry item No.40 of Part D of Ist schedule and therefore taxable at
\n12.5%.\n<\/p>\n
\t5. The contention of the learned counsel for the respondent is that an
\nalternative remedy against the impugned order of assessment is available under
\nSection 31 of the TNGST Act to the Appellate Assistant Commissioner which is not
\ndenied by the petitioner even in this Writ Petition.  It is the case of the
\npetitioner as submitted by the learned senior counsel that here is a case
\nwherein there is absolutely no jurisdiction on the part of the respondent in
\npassing the impugned assessment order, especially, in the circumstances that in
\nthe original assessment order itself, the total turnover as per the accounts in
\nrespect of turmeric has been found by the respondent as Rs.1,55,93,289\/-.  When
\nthat is the case, there is no absolutely question of suppression on the part of
\nthe petitioner and there is no reason for the purpose of revising the same.\n<\/p>\n
\t6. A reference to Section 16(2) of the Tamil Nadu General Sales Tax Act,
\nwhich is as follows:\n<\/p>\n
\tIn making an assessment under clause (a) of sub-section (1) the assessing
\nauthority may, if it is satisfied that the escape from the assessment is due to
\nwilful non-disclosure of assessable turnover by the dealer, direct the dealer,
\nto pay, in addition to the tax assessed under clause (a) of sub-section (a) by
\nway of penalty a sum which shall be-\n<\/p>\n
\t(a) fifty per cent of the tax due on the turnover that was wilfully not
\ndisclosed if the tax due on such turnover is not more than ten per cent of the
\ntax paid as per the return;\n<\/p>\n
\t(b) one hundred per cent of the tax due on the turnover that was wilfully
\nnot disclosed if the tax due on such turnover is more than ten per cent but not
\nmore than fifty per cent of the tax paid as per the return;\n<\/p>\n
\t(c) one hundred and fifty per cent of the tax due on the assessable
\nturnover that was wilfully not disclosed, if the tax due on such turnover is
\nmore than fifty per cent of the tax paid as per the return;\n<\/p>\n
\t(d)one hundred and fifty per cent of the tax due on the assessable
\nturnover that was wilfully not disclosed, in the case of self-assessment
\nreferred to in sub-section (1) of Section 12:\n<\/p>\n
\tProvided that no penalty under this sub-section shall be imposed unless
\nthe dealer affected has had a reasonable opportunity of showing cause against
\nsuch imposition.\n<\/p>\n
\t7. The above provision shows that the assessing authority can re-assess if
\nthere is a wilful non disclosure  of assessable turnover by the dealer.  In the
\npresent case, as it is seen in the original order of assessment passed by the
\nrespondent dated 05.03.2007, the assessing authority, the respondent himself has
\nexplained the turnover as per the account book in respect of turmeric as
\nRs.1,55,93,289\/-\/  However, in the pre-revision notice dated 15.03.2007, the
\nrespondent has chosen to presume as if the said turnover in respect of turmeric
\nas escaped assessment since it was sold in other state as branch sale.\n<\/p>\n
\t8. As it is seen, the said Section 16(1) of the Act,  which is subject to
\nSection 16(2) of the Act is based on the circumstances where there are wilful
\nnon disclosure of assessable turnover by the dealer.  Inasmuch as on the
\noriginal assessment, the said turnover has been considered by the respondent
\nhimself as per the accounts and the said order itself shows that the petitioner
\nhas produced the documents and filed form ‘F’ to prove that the petitioner has
\nactually transferred the goods to their branch office in other state for
\neffecting the branch sale there and having satisfied about the entire fact, the
\noriginal assessment order came to be passed.\n<\/p>\n
\t 9. In the light of the said factual position as found on record, I am of
\nthe considered view that no useful purpose will be served in driving the
\npetitioner to file an appeal to the appellate authority under Section 31 of the
\nTNGST Act.  The facts of the case would categorically show that there is prima
\nfacie reason to believe that the respondent’s assessment order is without
\njurisdiction.  By applying the judgment of the Supreme Court reported in Harbans
\nlal Sahnia and Another Vs. Indian Oil Corporation Limited reported in 2003(1)
\nCTC 189 (SC), it cannot be stated that availability of alternative remedy is a
\nbar for approaching this Court under Article 226 of the Constitution of India.\n<\/p>\n
\t10. Now going to the next contention of the learned senior counsel for the
\npetitioner as submitted by him, subsequent to the pre-revision notice, the
\npetitioner has sent a detailed objection stating that the purchase tax under
\nSection 7A of the Act is leviable only when the turnover of the dealer exceed
\nRs.300 crores in a year and it is stated that the purchase made by the
\npetitioner from M\/s.Aditya Trading Company, Erode, having TNGST Regn. No.775923
\ndated 25.04.2000 worth Rs.1,55,93,290\/- as against their proper bills and
\nturnover for the year 2005-2006 being Rs.715\/- lakhs which is well within the
\nlimit of Rs.300 crores for the year.  In respect of the re-assessment and
\nimposing of penalty under Section 16(2) of the TNGST Act, the petitioner has
\nfiled his objection, wherein he has clearly referred to the order of the TNGST
\nTribunal reported in (2005)139 CTC 294 (RUchi Soya Industries Limited V.
\nCommercial Tax Officer, Harbour-III Assessment Circle, Chennai and<\/a> another) to
\nsubstantiate its case that the petitioner is not liable for payment of penalty.\n<\/p>\n
\t11.In fact, the said judgment in Paragraph 12, it is stated that at the
\ntime of revising the assessment, the facts and figures were before the
\nassessment authority and only based on the said particulars furnished which are
\ncorrect, assessment order passed, and there was no wilful suppression so as to
\nwarrant a levy under Section 16(2) of the TNGST Act.  It was held that for the
\npurpose of imposing penalty under Section 16(2) of the TNGST Act, there should
\nbe an element of wilful non disclosure which is an essential aspect.
\nParagragraph 12 of the said judgment is as follows:\n<\/p>\n
\tPara 12. With regard to penalty levied under Section16(2) of the Tamil
\nNadu General Sales Tax Act, 1959 in all the cases, the learned Additional
\nAdvocate-General failrly concedes that penalty under section 16(2) won’t be
\nattracted.  On considering the records, I could see that while the first
\nrespondent was revising the assessment by levying purchase tax in the impugned
\norders, he says that the dealer has wilfully not declared the turnover liable to
\ntax under section 7-A(1)(c) of the Act in the monthly returns and paid tax due
\nthereon.  Thus, for suppressing the relevant turnover, he has levied penalty
\nunder Section 16(2) read with section 12(3) of the Act.  The levy is not
\nacceptable, since the facts and figures were already before the authorities even
\nat the time of original assessment and the petitioner was allowed exemption on
\nthe sales turnover of edible oil for all the years.  Only on noticing the
\nexemption given to the seller and the provisions in section 7-A, the first
\nrespondent has revised the assessments.  Thus, there was no wilful suppression
\nso as to warrant levy under section 16(2) of the Act.  For levying penalty under
\nsection 16(2), the element of wilful non-disclosure is essential, which is
\nabsent in these cases.  Therefore, in all the cases, the levy of penalty is
\ndeleted.\n<\/p>\n
\t12. In view of the above said factual position as found on record and the
\nsame has been raised as objections by the petitioner in the objections
\nexhaustively, it was the duty on the part of the second respondent to consider
\nthe said objections.  However a reference to the impugned assessment order shows
\nthat the objections were not at all taken in to consideration, even though, it
\nis stated that the objections have been filed by the petitioner even in respect
\nof imposing of penalty.\n<\/p>\n
\t13. In the absence of dealing with the said objections in their proper
\nperspective, I am of the considered view that the respondent should be directed
\nto consider the said legal as well as factual aspects in a proper manner and
\npass appropriate orders.  In view of the same, the impugned order of the
\nrevision of assessment passed by the respondent dated 25.02.2008 in
\nT.N.G.S.T.No.5300726\/05-06 is set aside and the same is remanded back to the
\nrespondent for fresh consideration of the entire aspect raised in the objections
\nby the petitioner in their communication dated 25.02.2008 and pass appropriate
\norders independently on merits and in accordance with law without being
\ninfluenced by any observations made herein.  Such order shall be passed by the
\nrespondent expeditiously, in any event, within a period of 12 weeks from the
\ndate of receipt of the copy of this order.\n<\/p>\n
\t14. The Writ petition is ordered accordingly.  No costs.  Consequently,
\nconnected M.P. is closed.\n<\/p>\n
arul\/dp<\/p>\n
To<\/p>\n
1.The Competent Authority and
\n   Additional Commissioner
\n  (Cinema and Irrigation),
\n  Land Administration Dept,
\n  Chepauk, Chennai – 5.\n<\/p>\n
2.The District Collector,
\n  Salem District.\n<\/p>\n
3.The Revenue Divisional Officer,
\n  Salem,
\n  Salem District.\n<\/p>\n
4.The Inspector of Police,
\n  Economic Offence – II
\n  Salem.<\/p>\n","protected":false},"excerpt":{"rendered":"
Madras High Court Sanat Product Limited vs Deputy Commercial Tax Officer on 18 June, 2008 BEFORE THE MADURAI BENCH OF THE MADRAS HIGH COURT DATED: 18\/06\/2008 CORAM THE HONOURABLE MR.JUSTICE P.JYOTHIMANI W.P.(MD)No.2728 of 2008 and M.P.(MD).No.1 of 2008 Sanat Product Limited, Ram Nagar, K.Rajadhani Kotai Kodai road, Dindigul. .. Petitioner Vs. Deputy Commercial Tax Officer, […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[8,13],"tags":[],"class_list":["post-210397","post","type-post","status-publish","format-standard","hentry","category-high-court","category-madras-high-court"],"yoast_head":"\nSanat Product Limited vs Deputy Commercial Tax Officer on 18 June, 2008 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/sanat-product-limited-vs-deputy-commercial-tax-officer-on-18-june-2008\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Sanat Product Limited vs Deputy Commercial Tax Officer on 18 June, 2008 - 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