Reassessment notices upheld where the earlier view was tentative, later judgments supplied material, and limited approval was sufficient.

Reassessment notices under Section 21 of the U.P. Trade Tax Act, 1948 were upheld because the earlier assessment view on the product was not final; the assessment order itself recorded that inquiry was continuing and further action could follow if adverse material emerged. The notices were also supportable on the basis of subsequent judicial decisions, which constituted relevant material for reopening. Approval by the Additional Commissioner was not invalid for lack of detailed reasons, since a speaking approval was not required and could suggest pre-judgment on the merits. The notices for the later years were additionally sustained because they extended to another product that had not been considered in the original assessments.

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Issues: Whether the notices for reassessment under Section 21 of the U.P. Trade Tax Act, 1948 were invalid for want of a final earlier determination, for being based on subsequent judicial decisions, and for alleged insufficiency of approval by the Additional Commissioner.

Analysis: The assessment order for the relevant year itself showed that the view then taken on the product was not final, because the order recorded that an inquiry was continuing and that further action would follow if adverse information emerged. The earlier view was therefore only tentative, and the reassessment could not be struck down on the ground that the issue had already been finally concluded. The notices were also supported by subsequent decisions, which constituted relevant material for initiating reassessment. As to the years requiring prior approval, the approving authority was not required to record elaborate reasons, since a detailed speaking approval could improperly suggest pre-judgment on the merits of the reassessment. The notices were further upheld because the reassessment for the later years covered an additional product for which there had been no discussion in the original assessments.

Conclusion: The reassessment notices were valid and not liable to be quashed.

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