Audit objection is not definite information for reassessment under sales tax law, so reopening cannot rest on it alone.

Reassessment under the Haryana General Sales Tax Act, 1973 is permissible only when the assessing authority has definite information showing under-assessment or escaped assessment. A mere audit objection or audit opinion that tax ought to have been levied does not satisfy that requirement, and reopening cannot rest only on a change of view prompted by an audit note. The stated position is consistent with the departmental circular cautioning against reassessment merely on audit objection. On that basis, an audit objection is not definite information for reassessment and reopening on that ground is not justified.

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Issues: Whether an audit note or objection constitutes "definite information" enabling reassessment under the Haryana General Sales Tax Act, 1973.

Analysis: Reassessment under section 31 is permissible only when the assessing authority acquires definite information leading to discovery of under-assessment or escaped assessment. A mere audit opinion that tax ought to have been levied does not amount to such information. Where the assessing authority merely changes its earlier view on receipt of an audit note, the statutory condition for reopening is not satisfied. The settled position was also reflected in the departmental circular advising against reassessment merely on audit objection.

Conclusion: An audit objection is not definite information for the purpose of reassessment, and the reopening was not justified.

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