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"9.In the considered view of this Court, the contention raised by the petitioner to state that there is error apparent on the face of the record, is not purely a legal issue but a mixed question of fact and law. The respondent has noted that the income-tax certification was passed apart from the Audit Report and Form-WW duly signed by a Chartered Accountant and the contention raised by the petitioner that certification holds good only for the purpose of income-tax assessment is not acceptable. Prima facie, this Court is of the view that such a finding recorded by the respondent is correct. Nevertheless, the matter involves appreciation and re-appreciation of the factual position, especially when the deemed assessments have taken place at the instance of the petitioner who filed the returns duly supported by Form-WW Certificates by a Chartered Accountant. Therefore, this Court cannot embark upon a fact-finding exercise to examine the correctness of the stand taken by the respondent to ascertain as to whether there is an error apparent on the face of the record. Admittedly, the revisional remedy before the Joint Commissioner is not only effective but also an efficacious remedy. Since the matter involves levy of tax, and there is enactment governing the transactions which provides for hierarchy of remedies, the petitioner should not be permitted to by-pass such alternative remedy available to the petitioner. 10.Thus for the above reasons, the preliminary issue is decided against the petitioner and it is held that the writ petitions are not maintainable."

7. Though, the appellant has contended that it was only an error apparent on the face of the record, upon consideration of the material on record, writ Court, vide common order made in W.P.Nos.21169 to 21171 of 2017, has observed that the income tax certification, holds good only for the purpose of income tax assessment. Writ Court has also observed that when the deemed assessment have taken place, at the instance of the petitioner, who had filed the returns, duly supported by Form-WW Certificates by a Chartered Accountant, writ Court cannot embark upon a fact-finding exercise to examine the correctness of the stand taken by the respondent therein, to ascertain as to whether there was an error apparent on the face of the record.

8. Though Mrs.R.Hemalatha, learned counsel for the appellant, invited the attention of this Court to the purchase and sale of cars, stated to have been taken place outside the State of Tamilnadu and further contended that State has no power to levy a tax and in that context there being a jurisdictional issue, Court can entertain a writ petition, we are of the view that under the scheme of the taxing statutes, even the question of jurisdiction, can always be raised before the concerned authorities. It is also to be seen that while considering the rectification petitions, filed under Section 84 of the Tamilnadu Value Added Tax Act, 2006, vide order dated 16.06.2017, the Assistant Commissioner (CT), Pondy Bazaar Assessment Circle, Chennai, has considered as to whether the case of the petitioner would fall under rectification or not. View of the said authority is that the mistake pointed out by the assessee/appellant is neither apparent from the returns filed nor reported in the audit report in Form-WW filed under Section 63A after due verification and certification by their auditors.