Reassessment notice validity turns on reason to believe and adequate notice of escaped turnover, not later proof of error.

A reassessment notice is valid where the assessing authority has material to form a reason to believe that turnover has escaped assessment, and the notice sufficiently informs the assessee of the proposed action. The notice is not rendered invalid merely because the underlying belief may later prove incorrect. On the facts stated, the notice referring to escaped turnover was treated as adequate, and the challenge based on mismatch between the issuing provision and the proposed Central sales tax assessment was rejected. The dispute over the substantive tax liability under the Central Sales Tax Act was left to be decided in the assessment proceedings.

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Issues: Whether the notice initiating reassessment proceedings was invalid because it was issued under section 21 of the U.P. Sales Tax Act while the escaped turnover was proposed to be assessed under the Central Sales Tax Act.

Analysis: The validity of a notice for escaped turnover depends on whether the assessing authority had reason to believe that part of the turnover had escaped assessment and whether the notice sufficiently informed the assessee of the proposed action. A notice is not invalid merely because the underlying belief may later prove erroneous, so long as there was material on which the belief could reasonably be formed. The notice here stated that part of the turnover for the relevant year had escaped assessment, and the surrounding circumstances made it clear that the proposed action related to Central sales tax liability. The court therefore treated the challenge to the notice as separate from the merits of liability under sections 8(2A) and 9 of the Central Sales Tax Act, which were left to the assessment proceeding.

Conclusion: The notice was held valid and the challenge to it failed.

Final Conclusion: The petition was dismissed, with the reassessment notice sustained and the merits of the tax liability left to be determined in the pending assessment proceedings.

Ratio Decidendi: A reassessment notice is valid if the assessing authority has reason to believe that turnover has escaped assessment and the notice sufficiently conveys the proposed action, even if the assessee disputes the underlying tax liability.

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