Reassessment requires fresh material later discovered; an earlier omission or lack of diligence cannot justify reopening without jurisdiction.

Reassessment under section 14(4) of the Andhra Pradesh General Sales Tax Act, 1957 is permitted only when fresh material, unavailable at the time of the original assessment, later comes to the assessing authority's notice. If the relevant material was already on record and the earlier officer merely failed to notice or properly apply it, that omission does not justify reopening. On the facts described, no new material emerged after the original assessment, so the reassessment was held to be without jurisdiction and was set aside in favour of the assessee.

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Issues: Whether reassessment under section 14(4) of the Andhra Pradesh General Sales Tax Act, 1957 was sustainable when no fresh material, distinct from the material available at the time of the original assessment, had come to the notice of the successor assessing authority.

Analysis: Reassessment under section 14(4) is justified only when material not available at the time of the original assessment subsequently comes to the notice of the authority from an external source or otherwise after the assessment. If the relevant material was already on record and the original assessing authority failed to advert to it because of lack of diligence or non-application of mind, that circumstance does not confer power to reopen the assessment under section 14(4). The basis of the power is the later emergence of material, not merely the discovery that the earlier assessment was careless.

Conclusion: Reassessment was not valid because no fresh material had emerged after the original assessment; the order could not be sustained and was set aside in favour of the assessee.

Final Conclusion: The reassessment was held to be without jurisdiction on the facts, and the revision succeeded.

Ratio Decidendi: Power of reassessment under section 14(4) cannot be invoked merely to correct an earlier omission or lack of diligence when the relevant material was already available at the time of the original assessment; it requires subsequent discovery of fresh material.

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