Independent reason to believe is essential for sales tax reassessment; notice based only on another officer's letter was quashed.

Reassessment under section 21(1) of the U.P. Sales Tax Act required the assessing authority to form its own reason to believe, based on relevant record or material, that turnover had escaped assessment. A mere letter from another sales tax officer, without independent scrutiny of the record, was insufficient to confer jurisdiction or satisfy the statutory precondition for notice. The reassessment notice and proceedings were therefore invalid and were quashed in favour of the assessee.

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Issues: Whether reassessment proceedings under section 21(1) of the U.P. Sales Tax Act, 1948 were valid when the assessing authority acted only on another officer's letter without independently examining the relevant material and forming its own reason to believe that turnover had escaped assessment.

Analysis: The reassessment power could be exercised only if the assessing authority itself had reason to believe, on the basis of relevant record or material, that turnover had escaped assessment. A mere communication from another sales tax , unsupported by the assessing authority's independent scrutiny of the record, was insufficient. Jurisdiction under section 21 could not be assumed on conjectures or on the satisfaction of some other authority. Since the assessing authority did not itself examine the material and merely acted on the letter, the statutory precondition for issuing notice was not met.

Conclusion: The reassessment notice and the proceedings initiated under section 21(1) were invalid and were quashed, in favour of the assessee.

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