JUDGMENT :

(Prayer: Writ Petition is filed under Article 226 of Constitution of India, to issue a Writ of Certiorarified Mandamus, calling for the records in ROC.No.A11/1800/2021 dated 15.03.2021 issued by the first respondent and quash the same as illegal, arbitrary and further direct the first respondent to pass an order afresh after affording reasonable opportunity of being heard to the petitioner within such time as may be directed by this Court.)

1. Since the petitioner in all these writ petitions is the same Assessee or dealer and the issue raised in all these writ petitions are one and the same in respect of various assessment years, by consent of the learned counsel appearing for both sides, all the writ petitions are heard together and are disposed of by this common order.

2. As against the petitioner in respect of assessment years 2008-2009 to 2014-2015 assessment orders have been passed by the second respondent, by order dated 20.06.2017. The said order had been challenged by the petitioner in a batch of writ petitions in W.P(MD).Nos. 2023 and 2029 of 2018 on the ground that there has been a violation of principles of natural justice. A learned Judge of this Court having entertained those writ petitions passed the following order by his order dated 06.02.2018 which reads thus:

“2. The petitioner was issued with pre-revision notice. In response thereto, the petitioner submitted a letter seeking grant of further time. Without formally considering the said request for grant of further time, the respondent chose to pass the final order. The final orders are vitiated for not having afforded due opportunity to the petitioner. Since the final orders have clearly infringed the principles of natural justice, this Court is inclined to quash the same. The matters are however remitted to the file of the respondent with liberty to pass fresh orders after affording due opportunity to the petitioner.

3. With this liberty, these writ petitions stand allowed. No Costs. Consequently, connected miscellaneous petitions are closed.”

3. Accordingly, the matters had been remitted back to the second respondent-assessing authority to re-assess and pass a fresh order. Accordingly, the issue had been reconsidered and fresh orders had been passed by the second respondent for each of the assessment year as referred to above by a series of the orders on 21.01.2020, where the earlier assessment order has been reiterated by the second respondent. Having aggrieved over the said batch of revised orders passed for various assessment years by the second respondent dated 21.01.2020, the petitioner could have filed an appeal before the appellate authority under Section 51 of the Tamil Nadu Value Added Tax Act, 2006, (hereinafter referred to as “the Act”), however, according to the petitioner, in the said revised orders passed by the assessing authority, i.e., the second respondent, since there has been an apparent mistake occurred, in order to rectify the same, the petitioner having invoked Section 84 of the Act has given request/representation on 07.12.2020, separately for each of the assessment year.

4. However, the second respondent, instead of entertaining and deciding the said representation or request given by the petitioner separately for each of the assessment year under Section 84 of the Act for the purpose of rectifying the alleged mistake, had issued a notice dated 07.01.2021 in respect of all these cases separately, wherein the second respondent has simply stated that the petitioner had given explanation on 07.12.2020, which was received by the second respondent office on 09.12.2020 and in this context, since there has been provision available under the Act, especially under Section 51 to file appeal to the appellate Deputy Commissioner r/w Rule 14 of the Rules made thereunder, the petitioner/dealer should have filed an appeal against the revised assessment order dated 21.01.2020, instead, since he has given a representation, such kind of represen