Reassessment on escaped turnover may consider later-discovered material once proceedings are validly opened within limitation.

Reassessment under the U.P. Sales Tax Act may proceed on the basis of additional material received after the limitation period, so long as proceedings were validly initiated in time on a reasonable belief that turnover had escaped assessment. The reopening provision requires only reason to believe that the whole or part of the turnover escaped assessment, and it does not confine completion of reassessment to the exact material originally relied on in the notice. The commentary notes that analogous income-tax reassessment principles support consideration of later information during the permitted reassessment period.

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Issues: Whether, when reassessment proceedings are validly initiated within limitation on the basis of information that part of the turnover has escaped assessment, further information received after expiry of the limitation period can be taken into account while completing the reassessment under section 21 of the U.P. Sales Tax Act.

Analysis: The reopening provision required only that the assessing authority have reason to believe that the whole or any part of the turnover had escaped assessment. Once proceedings were validly commenced within the prescribed period on a reasonable belief, the provision did not confine the authority to the precise items originally forming the basis of the notice. The completion of the reassessment within the further period allowed by law could proceed on the basis of additional material received in the meantime. The analogous position under income-tax reassessment provisions supported this approach.

Conclusion: The additional information received after expiry of the four-year period could be considered in the reassessment proceedings, and the question was answered in the affirmative against the assessee.

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