Fresh material is required for reassessment; an earlier assessment cannot be reopened merely for alleged legal error.

A successor-assessing authority cannot reopen a completed matter and issue a reassessment notice unless fresh material exists to justify interference. The controlling test under section 14(4) is the presence of new material, not whether the earlier assessment was legally correct. Where no fresh material is available, reassessment cannot be sustained merely because the prior order may have been erroneous in law. The challenge therefore succeeded and the reassessment notice was held unjustified.

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Issues: Whether a successor-assessing authority could reopen the matter and issue notice for reassessment in the absence of fresh material.

Analysis: The notice for taxing the turnover was issued after the earlier proceedings had been dropped. The controlling test for exercise of power under section 14(4) was whether there was fresh material justifying interference, not whether the earlier assessment order was legally correct. In the absence of fresh material, a subsequent assessment could not be made merely because the earlier order was erroneous in law.

Conclusion: The reassessment was not justified for want of fresh material, and the challenge succeeded.

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