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Kerala High Court5 March 2026

SL Format Architects v. State of Kerala

Single judge · Justice Amit Rawal

Why it matters

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Advocates handling Kerala VAT assessment challenges should verify whether a notice invoking Section 25A actually references a CAG report; absence of that reference collapses the Section 25A basis and confines the matter to Section 25(1), making a writ challenge to the vires of Section 25A untenable — the appropriate remedy being the statutory appeal, with limitation protected if the writ is withdrawn on this ground.

Summary

M/s. SL Format Architects Pvt. Ltd., a Mumbai-based architecture firm, had filed this writ petition before the Kerala High Court challenging proceedings initiated by the Commercial Tax Officer (WCT) and the Inspecting Assistant Commissioner, Commercial Taxes, Ernakulam, arising out of an assessment for the year 2009-2010. The petitioner had also sought relief in connection with a Revenue Recovery Notice (Ext.P3) and an Assessment Order (Ext.P4) dated 11.04.2017.

During the course of hearing on admission, counsel for the petitioner, upon closer examination of the impugned notice, conceded that although the notice purported to have been issued under Section 25A of the relevant Act, its contents were in fact referable only to Section 25(1), inasmuch as there was no reference to any report of the Comptroller and Auditor General of India — a prerequisite for invoking Section 25A. The assessment order Ext.P4 had also been passed under Section 25(1) alone. Confronted with this position, counsel acknowledged that the challenge to the vires of Section 25 would not survive and sought leave to withdraw the petition with liberty to pursue the statutory appellate remedy.

The Court permitted withdrawal of the writ petition and granted liberty to file an appeal within one month from the date of receipt of a copy of the judgment. The Court further directed that if such an appeal is filed, no objection as to limitation shall be raised, and the Appellate Authority shall decide the appeal on merits within three months.

Key principle

A notice purportedly issued under Section 25A of the Kerala VAT Act but lacking any reference to a Comptroller and Auditor General report — the essential jurisdictional trigger for Section 25A — must be treated as a notice under Section 25(1) alone, foreclosing any challenge to the vires of Section 25A in such proceedings.

Holding

Disposed of — the writ petition was permitted to be withdrawn with liberty to file a statutory appeal within one month, with the Appellate Authority directed to condone limitation and decide the appeal within three months.

Statutes invoked

  • Kerala Value Added Tax Act · 25(1)
  • Kerala Value Added Tax Act · 25A

Practice areas

writtax
AI-generated summary, written by Claude Sonnet 4.6 from the court's published judgment. Always verify the original before relying on the summary in court. Generated on 21 May 2026.