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TMI Blog2021 (11) TMI 167X X X X Extracts X X X X X X X X Extracts X X X X ..... ted in any law journal. Therefore, this Court deems it appropriate to give the writ petition number and date of the order for convenience of all concerned. It may not be necessary to delve further into State Bank of India officers case as that was a case where 'reasonable opportunity to show cause' occurring in the common proviso to sub-sections (1) and (2) of Section 27 of TNVAT Act and the expression 'reasonable opportunity of being heard' occurring in the proviso to sub-section (4) of Section 22 of TNVAT Act were considered, distinguished and explained. That may not be of great significance in the case on hand as the simple point urged by learned counsel for writ petitioner is, impugned order has been made without ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s made is not mentioned. Be that as it may, this position makes the matter on hand a little more complex owing to a note in the impugned order and more particularly, Note No.1, which says that the impugned order is subject to revision under Section 27 of 'Tamil Nadu Value Added Tax Act, 2006 (Tamil Nadu Act 32 of 2006)', which shall hereinafter be referred to as 'TNVAT Act' {for the sake of convenience and clarity} read with Section 9(2) of 'Central Sales Tax Act, 1956' ('CST Act' for the sake of brevity). 3. Mr.B.Raveendran, learned counsel for writ petitioner submits that a perusal of the order makes it clear that the impugned order itself has been made under Section 27 of TNVAT Act and the writ petition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... formed that this order was carried in appeal by way of an intra-court appeal vide W.A.No.4073 of 2019 and a Hon'ble Division Bench of this Court dismissed the writ appeal vide order dated 16.12.2019. Therefore the order made by this Court in State Bank of India officers case has merged with the order of Hon'ble Division Bench. 7. It may not be necessary to delve further into State Bank of India officers case as that was a case where 'reasonable opportunity to show cause' occurring in the common proviso to sub-sections (1) and (2) of Section 27 of TNVAT Act and the expression 'reasonable opportunity of being heard' occurring in the proviso to sub-section (4) of Section 22 of TNVAT Act were considered, disti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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