STATE OF MADRAS vs P.M. BATCHA & COMPANY

The Supreme Court ruled that under Section 11 of the Madras General Sales Tax Act, 1939, no appeal could be filed against a 'Nil' assessment since no tax was assessed or taxable turnover determined. The Court held that the Deputy Commissioner of Commercial Taxes had the jurisdiction to initiate re-assessment proceedings under Section 32 of the Madras General Sales Tax Act, 1959, despite the prior 'Nil' assessment not being communicated to the assessee. The High Court's ruling was overturned, affirming the Deputy Commissioner's authority to revise the assessment order.