Reassessment cannot rest on a mere change of opinion without fresh material supporting reopening.

Reassessment under the U.P. Trade Tax Act could be initiated only where the Assessing Authority had reason to believe, on relevant fresh material, that turnover had escaped assessment or deductions were wrongly allowed. A mere different view on the same facts already examined in the original assessment was insufficient. Because the reopening relied only on the Commissioner's circular and the same material previously considered, without any new facts or additional evidence, it amounted to a change of opinion and could not lawfully sustain reassessment. The reopening was therefore invalid.

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Issues: Whether reassessment proceedings could be initiated under Section 21 of the U.P. Trade Tax Act, 1948 merely on a change of opinion, without any new or additional material on record.

Analysis: The statutory scheme required the Assessing Authority to have reason to believe that turnover had escaped assessment or that deductions had been wrongly allowed. That belief had to rest on relevant material having a rational connection with the proposed reopening. A mere different view on the same material already considered in the original assessment could not satisfy the statutory precondition. The reopening in the present case was founded only on the Commissioner's circular and the same set of facts that existed at the time of the original assessment, without disclosure of any fresh material or new facts. Such reopening amounted only to a change of opinion, which cannot by itself justify reassessment under Section 21(1).

Conclusion: Reassessment proceedings could not be sustained merely on a change of opinion and were invalid in the absence of fresh material; the issue was decided against the assessee's opponents and in favour of the respondent.

Ratio Decidendi: Reassessment can be validly initiated only when the Assessing Authority has reason to believe, based on relevant and fresh material, that income or turnover has escaped assessment; a mere change of opinion on the same material is not a lawful ground for reopening.

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