Objective material is required to reopen concluded assessments; subjective satisfaction alone cannot justify reassessment notices.

Notices to reopen completed assessments under section 16 of the Tamil Nadu General Sales Tax Act must rest on objective material showing a genuine reason to reopen. The court noted that concluded assessments had attained finality, earlier scrutiny had accepted the sales as second sales, and the records disclosed no factual basis supporting reopening. Because the authority relied only on subjective satisfaction, the invocation of section 16 was not authorised, and the reopening notices were held jurisdictionally invalid.

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Issues: Whether notices issued to reopen completed assessments under section 16 of the Tamil Nadu General Sales Tax Act were valid in the absence of objective material showing reason to reopen.

Analysis: The completed assessments for the relevant years had become final, and the records did not disclose any objective basis for reopening them. The power to revise or reopen an assessment under section 16 is wide, but it must be exercised cautiously and only on material that can satisfy an objective test. Mere subjective satisfaction of the authority is insufficient. In the circumstances, where earlier scrutiny had accepted the sales as second sales and no reason for reopening was shown, the invocation of section 16 was not authorised.

Conclusion: The reopening notices were jurisdiction and invalid; the challenge succeeded.

Ratio Decidendi: Reassessment or revision of a concluded assessment requires objective material demonstrating a reason to reopen, and cannot rest solely on the authority's subjective satisfaction.

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