mere apprehension that, on the petitioner being permitted to pay the differential tax, he might lay claim to the input tax credit of tax paid on purchases that were not reported, cannot, in my view, be a ground to deny the petitioner the opportunity to come forward and rectify an anomaly in the returns, so as to ensure a compliance with the statutory provisions. The statutory provisions which deal with the revision of returns, and the procedure to be complied there for, are to be found in Sections 22, 31 and 42 of the KVAT Act and Rule 22 of the Kerala Value Added Tax Rules [hereinafter referred to as the 'KVAT Rules']. A perusal of the said provisions would indicate that an opportunity is granted to an assessee to revise returns, on his detecting omissions, and then, if no objections are raised by the Department, the assessment itself is deemed to be complete based on the returns filed by the assessee. Rule 22 of the KVAT Rules enables a dealer to revise returns within a period of two months from the last date of the return period to which the return relates. A proviso to the said Rule suggests that the Rule will not apply to a dealer against whom penal action is initiated for the same materials as necessitated the revision of the returns. The statutory provisions are silent, however, with regard to the course of action to be adopted in respect
