8.Insofar as the present prayer for seeking direction to the first respondent to decide the rectification petition filed by the petitioner under Section 84 of TNVAT Act dated 20.07.2021, with regard to the objection raised by the learned Government Advocate pertaining to the limitation is concerned, the learned counsel appearing for the petitioner would contend that, the petitioner along with others had challenged the very provision in writ petitions, which were pending for long years and it was decided on 03.10.2019 and a copy of the order had been served only on 15.07.2021. Only on receipt of the said order, the present rectification petition under Section 84 of TNVAT Act had been filed on 20.07.2021, that is, within a week period and therefore, the time period during the pendency of the earlier proceedings, where the petitioner and others had enjoyed the benefit of stay is to be excluded, in that case, certainly, the present rectification petition filed under 84 of TNVAT Act would come within the purview of five years limitation period. Therefore, it cannot be stated that it is beyond the limitation of five years. Therefore, the application submitted by the petitioner under Section 84 of TNVAT Act can very well be considered, on merits by the first respondent, within the time frame as may be stipulated by this Court, he contented.
