Reassessment requires specific, year-linked material; vague third-party information and suspicion cannot justify reopening under tax law.

Reassessment under the U.P. Trade Tax Act cannot rest on vague or unrelated material that does not link the information to the relevant assessment year. Where the notice is based only on suspicious cash entries, lacks year-specific details, and relates to another dealer, the foundation for reopening is not specific enough to sustain reassessment. The Tribunal treated such material as incapable of supporting a valid belief of escapement, and reassessment based on surmise and conjecture was set aside.

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Issues: Whether reassessment could be sustained when the material forming the basis of the notice was vague, unrelated to the relevant assessment year, and only raised suspicion.

Analysis: The reassessment was initiated under Section 21 of the U.P. Sales Tax Act, as then called the U.P. Trade Tax Act, on information said to relate to gunny bags. The Tribunal found that the information did not mention gunny bags, contained only cash entries with no year against the dates, and related to another dealer. On that basis, it held that the material was neither specific nor capable of being linked to the assessment year in question. It further held that reassessment cannot rest on surmises and conjectures alone.

Conclusion: The reassessment was rightly set aside and the revision failed.

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