ORDER S. NAGAMUTHU :- Since common issues are involved in these writ petitions, they were all heard together and they are disposed of by means of this common order. The petitioner in all the writ petitions, viz., Dharani Sugars and Chemicals Limited at Vasudevanallur in Tirunelveli District is a company incorporated as per the provisions of the Companies Act of 1956. The petitioner - company has got sugar mill at Vasudevanallur in Tirunelveli District. The said mill was set up to manufacture sugar and its commercial production commenced in the year 1989. Prior to 1988, in order to encourage the sugar industries, the Government had granted subsidy to the sugar mills on par with the purchase tax. According to the petitioner, the petitioner also believed that such subsidy would be extended to the petitioner mill also. However, the Government did not extend such subsidy facility to the petitioner. Instead, the Government issued G.O.Ms. No. 989, dated September 1, 1988, under which the Government introduced a deferral scheme, i.e., the subsidy was done away with and instead, there was a tax deferral for four years. The said Government order was extended even to the private mills. To put it precisely, the benefit of the subsidy extended even to the private mills as per G.O.Ms. No. 1294, dated October 24, 1975 and G.O.Ms. No. 268, Industries (MID.I.) Department, dated April 16, 1987, were done away with. The petitioner was aggrieved by G.O.Ms. No. 989, dated September 1, 1988. Therefore, the petitioner challenged the said Government order on several grounds including on the ground of legitimate expectation. When the said writ petition was pending, provisional demands were made and consequently, recovery proceedings were also initiated. The petitioner challenged the same by filing writ petitions in W.P. Nos. 4685 and 4686 of 1993. These two writ petitions were subsequently transferred to Taxation Appellate Tribunal and they were tried as original petitions and they were dismissed. Challenging the same, the petitioner filed writ petitions in W.P. Nos. 11419 and 11420 of 1999. These two writ petitions were dismissed by a Division Bench of this court on November 27, 2001 ([2002] 128 STC 554 (Mad)). A special leave petition filed before the honourable Supreme Court was also dismissed. Challenging the same, the petitioner filed writ petitions in W.P. Nos. 11419 and 11420 of 1999. These two writ petitions were dismissed by a Division Bench of this court on November 27, 2001 ([2002] 128 STC 554 (Mad)). A special leave petition filed before the honourable Supreme Court was also dismissed. When the above litigations are pending elsewhere, the first respondent proceeded to make final assessments as per section 12 of the Tamil Nadu General Sales Tax Act of 1959 (hereinafter referred to as, "the Principal Act") and in certain respects, under section 16 of the Act. Such assessment orders passed by the first respondent were all taken up on appeals under section 31 of the Principal Act before the Appellate Assistant Commissioner. The Appellate Assistant Commissioner partly confirmed the assessment and in other respects, he modified the same. The petitioner filed further appeals before the Sales Tax Appellate Tribunal under section 36 of the Principal Act. In the appeals, the petitioner contended that in view of the proceedings pending in respect of G.O.Ms. No. 989, wherein the petitioner was pleading that exemption from purchase tax on the ground of subsidy, he also challenged the very levy of purchase tax. The other contention was, in the alternative, assuming that the petitioner is liable to pay purchase-tax, still on certain aspects, the petitioner enjoys the purchase tax exemption. In other words, it was the contention of the petitioner that the planting subsidy and transport subsidy, etc., should not be subjected to tax, as they are not being priced at all. When these appeals pertaining to nine assessment orders were pending, on June 3, 2002, the Tamil Nadu Act 17 of 2002 was gazetted. As it is seen from the Statement of Objects and Reasons of the said Act, it was the Act to provide for expeditious settlement of disputes relating to arrear of tax, penalty or interest pertaining to sales tax and the matters connected therewith or incidental thereto. Under section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002, provision was made for settlement of dispute by issuance of certificate by the competent authority. Section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002 reads as follows : "8. Settlement of dispute and issue of certificate. Under section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002, provision was made for settlement of dispute by issuance of certificate by the competent authority. Section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002 reads as follows : "8. Settlement of dispute and issue of certificate. - (1) The designated authority, on being satisfied about the payment of the amount determined under sub-section (1) of section 6 shall, by an Order, settle the dispute and issue a certificate in such form as may be prescribed, and thereupon the applicant shall be discharged from his liability to make payment of the balance amount of such arrear of tax, penalty or interest. Separate certificate shall be issued in respect of each application. (2) The designated authority may, for reasons to be recorded in writing, refuse to settle a dispute : Provided that no order under this sub-section shall be passed without giving the applicant a reasonable opportunity of showing cause against such refusal. (3) The authority notified by the Government in this behalf may, at any time within ninety days from the date of issue of certificate under sub-section (1) by the designated authority, modify the certificate by rectifying any error apparent of the face of the record : Provided that no such rectification adversely affecting the applicant shall be passed without allowing the applicant a reasonable opportunity of showing cause against such rectification." For requesting for settlement of dispute, the assessee is required to make an application under section 5 of the Act in form I as per rule 3(1) of the Tamil Nadu Sales Tax (Settlement of Disputes) Rules of 2002 to the designated authority. On considering the said application, under section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002, the designated authority may issue a certificate. If once such a certificate is issued, under section 10 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002, the appeal or revision pending before the appellate authority or revisional authority, as the case may be, under the relevant Act, in respect of which, a certificate has been issued under section 8, shall be deemed to have been withdrawn by the applicant from the date of making of the application by the applicant under sub-section (1) of section 5. Under section 12 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002 the designated authority has been empowered to revoke the certificate on certain circumstances, which reads as follows : "12. Revocation of certificate. - (1) Notwithstanding anything contained in section 9 or section 10, where it appears to the designated authority that an applicant has obtained the certificate under this Act by suppressing any material information or particulars or by furnishing any incorrect or false information or particulars, such designated authority, may, within a period of two years from the date of issue of certificate for reasons to be recorded in writing and after giving the applicant a reasonable opportunity of showing cause, revoke the certificate issued under sub-section (1) of section 8. (2) If a certificate is revoked under sub-section (1), the appeal or revision, as the case may be, under the relevant Act, covered by such certificate, shall, notwithstanding the provisions of section 9 or section 10, stand revived or reinstated immediately upon such revocation, and such appeal or revision shall be decided in accordance with the provisions of the relevant Act, as if no settlement of the arrear of tax, penalty or interest in dispute in such appeal or revision has ever been made under this Act. (3) In the case of revocation of a certificate in accordance with sub-section (1), the amount paid by the applicant under this Act shall be treated as payment towards the amount payable under the relevant Act for the period for which the certificate has been issued." In this case, since according to the petitioner, the appeals in respect of nine assessment orders from 1988 to 1996 were all pending before the Sales Tax Appellate Tribunal, the petitioner made nine individual applications in form I requesting for settlement of disputes involved in such appeals. The application was made in form I in each case. Having considered all the above, the designated authority, viz., the second respondent herein, issued certificate of settlement in form TV on May 9, 2003. Accordingly, the petitioner made payment of tax as per the said settlement in all the matters. While so, the second respondent, viz., the designated authority issued notice on April 26, 2005 in all the cases, calling upon the petitioner to show cause as to why the certificates should not be revoked under section 12 of the Act. Accordingly, the petitioner made payment of tax as per the said settlement in all the matters. While so, the second respondent, viz., the designated authority issued notice on April 26, 2005 in all the cases, calling upon the petitioner to show cause as to why the certificates should not be revoked under section 12 of the Act. It was alleged in the said show-cause notices that the issues were erroneously settled under section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002, because (i) the purchase tax exemption had been decided by the High Court in Dharani Sugars and Chemicals Ltd. v. Commercial Tax Officer, Sankaran Kovil [2002] 128 STC 554 (Mad) by judgment dated November 27, 2001; the exemption claimed on the tax-liability claimed on transport subsidy, planting subsidy, seed subsidy, cane development expenses had been decided on December 17, 1999 by the honourable Supreme Court in the case of E.I.D. Parry (I) Ltd. v. Assistant Commissioner of Commercial Taxes reported in [2000] 117 STC 457. Therefore, according to the show-cause notice, the certificates issued were all wrongly issued on misrepresentation committed by the petitioner - company. The petitioner - company submitted objections in all the cases on May 2, 2005, wherein the petitioner contended that there was no misrepresentation committed at all by the petitioner. It was further contended that all the particulars, which are required in form I, were all duly submitted. It was also contended that the issues in the earlier litigations have got nothing to do with the final assessment order made and further, the pendency of the earlier proceedings and disposal of the same were all very much within the knowledge of the second respondent, even while he decided all these matters to issue certificates. Therefore, absolutely, there was no misrepresentation committed by the petitioner. It was further contended that since as on date, the appeals were pending, there was nothing illegal in the matter of granting the certificates. But, it was stated in the show-cause notices that the appeals were not in the legal sense, real appeals and there were attempts made to reopen the closed issues. Therefore, pendency of the so-called appeals before the Sales Tax Appellate Tribunal cannot be construed as appeals at all for the purposes of section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002. Therefore, pendency of the so-called appeals before the Sales Tax Appellate Tribunal cannot be construed as appeals at all for the purposes of section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002. This stand taken in the show-cause notice was also disputed. According to the petitioner, since the disputes, which came up for decision in the earlier proceedings, have got nothing to do with the final assessment orders and since the final assessment orders came to be passed during the pendency of those proceedings and the appeals were also filed during the pendency of those proceedings, it cannot be stated as sham. Having considered the above objections, the second respondent, by a common order dated May 6, 2005, rejected those objections and finally, revoked all the nine certificates. Challenging the same, the petitioner has come up with these writ petitions. In the counter-affidavit filed by the second respondent, in paragraph No. 4, it has been stated as follows : "4. It is respectfully submitted that the issue relating to levy of tax on the purchase of cane was already decided by the honourable Tamil Nadu Taxation Special Tribunal, Chennai in T.P. Nos. 77, 78, 1223 and 612/98 dated June 11, 1999 by way of dismissing the original petitions holding that the petitioners were not eligible for waiver (decision Dharani Sugars & Chemicals Ltd. v. Deputy Commercial Tax Officer reported in [1999] 115 STC 370 (TNTST)). The review petition filed by the petitioners before the honourable High Court of Madras in W.P. No. 1141 of 1999 was also dismissed by the court on November 27, 2001 (Dharani Sugars and Chemicals Ltd. v. Commercial Tax Officer, Sankaran Kovil [2002] 128 STC 554 (Mad)). Again, the subsidy issue was also decided by the honourable Supreme Court of India on December 17, 1999 in the case of E.I.D. Parry (I) Ltd., Chennai v. Assistant Commissioner of Commercial Taxes reported in [2000] 117 STC 457. So, the issues relating to levy of tax on the purchase value of sugarcane and subsidies could not be disputed by the petitioners in the appeal petition pending before the Sales Tax Appellate Tribunal (Additional Bench), Madurai as the issues were already settled by the higher judicial forums. Therefore, the petitioners cannot treat them as 'appeals pending' as on February 28, 2002." I have heard Mr. Therefore, the petitioners cannot treat them as 'appeals pending' as on February 28, 2002." I have heard Mr. C. Natarajan, learned senior counsel appearing for the petitioner and Mr. P. S. Raman, learned Advocate-General, assisted by Mr. Pala. Ramasamy, learned Special Government Pleader appearing for the respondents. I have also perused the records carefully. The first and foremost dispute, which is involved in these writ petitions, is as to whether there were appeals pending as on the date of coming into force of the Act, so that, the petitioner would be entitled for the certificates and whether the certificates were issued rightly or wrongly. The contention of the learned Advocate-General is that, of course, there were appeals pending in respect of nine matters before the Sales Tax Appellate Tribunal. But, these appeals, in the real legal sense of it, for the purpose of section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002, could be construed as appeals, because in these appeals, the issues, which had already been settled in the earlier proceedings, were all sought to be reopened. Therefore, according to the Advocate-General, these appeals cannot be construed as effective appeals for the purpose of section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002. The learned senior counsel appearing for the petitioner would submit that whether the appeal is ultimately maintainable and whether it will succeed or even whether it is sham or true, are all the matters, which have to be gone into only by the Appellate Tribunal and it is not for the designated authority under the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002 to come to such a conclusion. For this proposition, the learned senior counsel has relied on an earliest judgment of the honourable Supreme Court in Raja Kulkarni v. State of Bombay reported in AIR 1954 SC 73 , wherein the honourable Supreme Court has laid down that when a section contemplates the pendency of an appeal, what is required for its application is that an appeal should be pending and in such a case, there is no need to introduce the qualification that it should be valid or competent. Whether the appeal is valid or competent is a question entirely for the appellate court before whom the appeal is filed to determine and this determination is possible only after the appeal is heard, but there is nothing to prevent a party from filing an appeal which may ultimately be found to be incompetent, e.g., when it is held to be barred by limitation. From the mere fact that such an appeal is held to be unmaintainable on any ground whatsoever, it does not follow that there was no appeal pending before the court. The said judgment came up for consideration by the honourable Supreme Court in Tirupati Balaji Developers (P) Ltd. v. State of Bihar reported in [2004] 5 SCC 1, in which also, the honourable Supreme Court has held that an appeal does not cease to be an appeal though irregular and incompetent. These two judgments again came to be considered by the honourable Supreme Court in Commissioner of Income-tax v. Shatrusailya Digvijaysingh Jadeja reported in [2005] 277 ITR 435. In that case, the honourable Supreme Court, while approving the view taken in Raja Kulkarni AIR 1954 SC 73 and Tirupati Balaji Developers (P) Ltd.'s case [2004] 5 SCC 1, has held in paragraph Nos. 11 and 12, as follows : "11. The basic point which we are required to consider in this case is the meaning of the word 'pending' in section 95(i)(c) of the said Scheme. 12. The object of the scheme was to make an offer by the Government to settle tax arrears locked in litigation at a substantial discount. It provided that any tax arrears could be settled by declaring them and paying the prescribed amount of tax arrears, and it offered benefits and immunities from penalty and prosecution. In several matters, the Government found that a large number of cases were pending at the recovery stage and, therefore, the Government came out with the said scheme under which it was able to unlock the frozen assets and recover the tax arrears." While taking the above view, the honourable Supreme Court also had an occasion to consider the yet another judgment of the honourable Supreme Court in Dr. Mrs. Mrs. Renuka Datla v. Commissioner of Income-tax reported in [2003] 259 ITR 258, wherein the honourable Supreme Court has held that if the appeal or revision is pending on the date of filing of the declaration under section 88 of the scheme, it is not for the designated authority to hold that the appeal/revision was sham, ineffective or infructuous, as it has. From the above judgments, it is crystal clear that it is not for the designated authority to give a finding as to whether the appeal is sham, ineffective, infructuous, barred by limitation, valid, competent, regular, irregular or incompetent. These are all the matters which fall within the domain of the competent authority, viz., the Appellate Tribunal or Taxation Appellate Tribunal or any other authority before whom appeal or revision or reference is pending. It is not at all available for the designated authority under the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002 to decide the above matters. In the given cases, when the petitioner made applications for settlement, only after having considered these matters, the certificates were issued. In my considered opinion, the very issuance of show-cause notices, subsequently for the purpose of revoking the certificates on the ground that the certificates were obtained by making misrepresentation, cannot be accepted. In this regard, the learned senior counsel has relied on a judgment of the honourable Supreme Court in Shrisht Dhawan (Smt.) v. Shaw Brothers reported in [1992] 1 SCC 534, wherein the term "fraud" came to be considered by the honourable Supreme Court. In the said judgment, the honourable Supreme Court has held in paragraph No. 20 as follows : "20. ... From dictionary meaning or even otherwise fraud arises out of deliberate active role of representator about a fact which he knows to be untrue yet he succeeds in misleading the representee by making him believe it to be true. The representation to become fraudulent must be of fact with knowledge that it was false. ..." After having considered certain decisions, on this aspects in the very same paragraph, the honourable Supreme Court has further held as follows : "... It must result in exercise of jurisdiction which otherwise would not have been exercised. That is misrepresentation must be in relation to the conditions provided in a section on existence or non-existence of which power can be exercised. It must result in exercise of jurisdiction which otherwise would not have been exercised. That is misrepresentation must be in relation to the conditions provided in a section on existence or non-existence of which power can be exercised. But non-disclosure of a fact not required by a statute to be disclosed may not amount to fraud. ..." In the very same paragraph, the honourable Supreme Court further went on to say as follows : "... It is not misrepresentation under section 21 to state that the premises shall be needed by the landlord after expiry of the lease even though the premises in occupation of the landlord on the date of application or, after expiry of period were or may be sufficient. A non-disclosure of fact which is not required by law to be disclosed does not amount to misrepresentation. ..." Relying on the same, the learned senior counsel would submit that in this case, the petitioner has furnished all the details, which are required under form I. Therefore, there is no question of any misrepresentation on the part of the petitioner. As it has been held by the honourable Supreme Court, if only any fact which is required of from a party to be mentioned is suppressed, then it will amount to either fraud or misrepresentation. But, in this case, indisputably, in form I, which he made in all the cases, while seeking for settlement, the petitioner had given all the necessary details which are required under the form. Therefore, there is no misrepresentation at all. As held by the honourable Supreme Court, the petitioner is not required to furnish any additional information other than the information which was sought for in form I itself. In view of the settled position of law, in my considered opinion, I do not find any suppression of fact amounting to either misrepresentation or fraud. Now, once again turning to the question of pendency of appeals, the learned senior counsel would point out that under regulation 7 of the Tamil Nadu Sales Tax Appellate Tribunal Regulations of 1959, there is a specific procedure contemplated for registration of appeals by the Tribunal, which reads as follows : "7. Registration of appeals. - (1) On receipt of an appeal, the Secretary shall endorse on it the date of its receipt. Registration of appeals. - (1) On receipt of an appeal, the Secretary shall endorse on it the date of its receipt. The Secretary shall, thereafter, as soon as possible, examine; (i) Whether the person presenting it has the authority to do so; and (ii) Whether it conforms to the provisions of the Act, the rules and these regulations. If the Secretary is satisfied on these points, he shall cause it to be registered in a register to be kept for the purpose. (2) If the Secretary finds that the appeal does not prima facie fall under section 36(1) of the Act, he shall report to the Chairman who may either reject the appeal and order the papers to be returned to the party or fix a date for hearing the matter before the Tribunal after giving notice to the party and the State Representative and thereupon the provisions of regulation 7(5) below shall apply. (3) If the Secretary finds that the appeal does not conform to the requirements of the Act, the rules and these regulations, he shall call upon the party by a notice in form A in the schedule to these regulations to remedy the defect or defects within a reasonable period to be specified by him. The Secretary may for sufficient cause extend the period. If the defects are remedied within the period allowed, the Secretary shall cause the appeal to be registered. (4) When an appeal is represented without remedying the defects either within the period allowed or after the period allowed and where in the opinion of the Secretary it is considered that before admitting an appeal it is necessary to have the matter decided by the Tribunal, he shall make a report to that effect to the Chairman who may either reject the appeal or fix a date for hearing the matter and give due notice of such hearing to the party and the State Representative in form B in the Schedule : Provided that where an appeal is represented after the period allowed it shall be accompanied by a petition supported by an affidavit setting forth the facts, on which the appellant relies to satisfy the Tribunal that he has sufficient cause for not representing the appeal within such period. Such appeal shall not be admitted unless notice has been given to respondent and his objections have been heard and the Tribunal is satisfied that the appellant had sufficient cause for not representing the appeal in time. (5) On the date so fixed, the Appellate Tribunal shall, after hearing the party and the State Representative, pass orders directing either the registration of the appeal or its rejection. Where the appeal is rejected, the Appellate Tribunal shall record it reasons for doing so. (6) Where an appeal is presented after the period prescribed under the Act, it shall be accompanied by a petition supported by an affidavit setting forth the facts on which the appellant relies to satisfy the Tribunal that he had sufficient cause for not preferring the appeal within such period. Such appeal shall not be admitted unless notice has been given to the respondent and his objections have been heard and the Tribunal is satisfied that the appellant had sufficient cause for not preferring the appeal in time. (7) The appellants shall address the Secretary within a period of three months from the date of presentation or representation of their appeals presented have been registered if, by the time, they do not receive any communication in this regard from the Tribunal. The Tribunal shall not, thereafter, be responsible for any loss of appeal either in transit or otherwise. (8) As soon as may be after the registration of the appeal, the Secretary shall set a date for hearing and shall send an intimation thereof to the State Representative in form C in the Schedule. A copy of the memorandum of appeal and of the order appealed from shall also be furnished to him. It shall be the duty of the State Representative to obtain the records of the case from the Appellate Assistant Commissioner or the Deputy Commissioner, as the case may be, and transmit them to the Secretary." Referring to the above provision, the learned senior counsel would rightly contend that in this case, as provided under regulation 7(1), the appeals were all registered of all these appeals. As pointed out by the learned senior counsel, if only prima facie there are materials to admit the appeals and if only the person presenting has got authority to do so and that it conforms to the provisions of the Act, the rules and these regulations, on recording the satisfaction of the Secretary, the appeal shall be registered. In all these cases, the appeals were registered by the Secretary, because the appeals made out prima facie cases and also they conform to regulation 7(1) of the Regulation, Act, Rules, etc. When once the appeals have been admitted, as I have already stated, it is only for the Tribunal ultimately to decide whether these appeals are maintainable and whether these appeals are liable to be allowed or dismissed. It is not for the designated authority under this Act to give any finding as to whether the appeals are maintainable or not. Such finding by the designated authority is completely without jurisdiction. Apart from that, if any such finding is allowed to be given, the same will run counter to the decision of the statutory authority, viz., the Secretary of the Appellate Tribunal, who has got power to register an appeal on getting satisfied that it conforms to the provisions of the Act, Rules and it also make out a prima facie case. As it could be seen in the other sub-clauses of regulation 7, in the event if the Secretary is not satisfied about prima facie materials available on record, for the purpose of registering the appeal, then the matter will be listed before the Tribunal. The Tribunal, after hearing the parties, shall either register the appeal or reject the same. In these cases, even that occasion had not arisen for the petitioner to convince the Tribunal regarding the maintainability of the appeals, because these appeals were admitted at the threshold by the Secretary himself under clause 7(1) of the Regulation. Therefore, in my considered opinion, it is not at all within the jurisdiction and competence of the designated authority under this Act to say that the appeals are not real appeals in the legal sense for the purpose of section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002. Therefore, in my considered opinion, it is not at all within the jurisdiction and competence of the designated authority under this Act to say that the appeals are not real appeals in the legal sense for the purpose of section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002. For all these reasons, I hold that there were appeals pending as on the date of coming into force of the Act and, therefore, the case of the petitioner for settlement was rightly considered and decided in his favour. As I have already answered, there was no misrepresentation by the petitioner to the designated authority, when he decided the applications filed by the petitioner under section 5 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002. Nextly, the contention of the learned Advocate-General that the issues, which had already been decided either by this court or by the honourable Supreme Court or the Tribunal, have been again re-agitated by way of appeals before the Sales Tax Appellate Tribunal and, therefore, these appeals cannot be construed as appeals at all in the legal sense for the purpose of section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002 also cannot be countenanced. From the records, it could be seen that the earlier proceedings have got nothing to do with the final assessment orders. As a matter of fact, as I have already narrated, those proceedings relate to the validity of G.O.Ms. No. 989 and the provisional recoveries sought to be made and those proceedings have got nothing to do with the final assessment orders passed in all these matters. As a matter of fact, when these proceedings were pending, final assessment orders were passed and such final orders were challenged by way of appeals to the appellate authority, then to the Sales Tax Appellate Tribunal under section 36 of the Act. Indisputably, all these appeals in question were all filed even during the pendency of the earlier proceedings. Therefore, it cannot be said that - these appeals have been filed with a view to get the benefits of the Scheme which was not even in force in those days. The Scheme itself was introduced long after the registration of these appeals. Therefore, this objection raised by the learned Advocate-General also deserves only to be rejected. Therefore, it cannot be said that - these appeals have been filed with a view to get the benefits of the Scheme which was not even in force in those days. The Scheme itself was introduced long after the registration of these appeals. Therefore, this objection raised by the learned Advocate-General also deserves only to be rejected. In view of all the above, I find that there is nothing illegal in granting the certificates to the petitioner in all the cases under section 8 of the Tamil Nadu Sales Tax (Settlement of Disputes) Act of 2002 and I hold that the revocation of such certificates by means of the impugned orders cannot be held to be legal. Therefore, I am inclined to quash all the revocation orders and allow these writ petitions. In the result, the writ petitions are allowed and the impugned orders are set aside. Consequently, connected W.P.M.Ps. and W.V.M.Ps., are closed. No costs.