Reassessment under sales tax law requires material-based belief of escaped turnover; conjecture alone cannot justify reopening a completed assessment.

Section 21 of the U.P. Sales Tax Act permits reopening a completed assessment only where the assessing authority has material giving rise to a reasonable belief that turnover has escaped assessment. Reassessment cannot rest on conjecture, a mere later verification exercise, or the officer's unsupported assumption that electricity consumption or other information was not examined earlier. On the stated facts, the escaped turnover estimate was found to be without material and based on guesswork, so the supplementary assessment and demand notice were invalid and were quashed.

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Issues: Whether the supplementary assessment and notice under section 21 of the U.P. Sales Tax Act were valid when there was no material showing escapement of turnover.

Analysis: Section 21 can be invoked only where the assessing authority has reason to believe, on the basis of material, that turnover has escaped assessment. Reopening a completed assessment merely to verify information received later, or because a matter such as electricity consumption had not been checked at the original assessment, is insufficient. The escaped turnover estimate was found to rest on no material and to be a mere guess, making the reassessment arbitrary and unsustainable.

Conclusion: The supplementary assessment and the notice of demand were invalid and liable to be quashed.

Final Conclusion: Relief was granted to the petitioner by setting aside the reassessment proceedings for want of supporting material.

Ratio Decidendi: A completed sales tax assessment can be reopened under section 21 only on the basis of material giving rise to a reasonable belief that turnover has escaped assessment; a reassessment founded on conjecture or the assessing officer's ipse dixit is invalid.

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