Reassessment requires recorded reasons and fresh material; mere change of opinion on disclosed turnover is impermissible.

Reassessment under Section 24(1) of the Delhi Sales Tax Act, 1975 was unsustainable because the Assessing Authority had not first recorded reasons to believe, on relevant material, that turnover had escaped assessment, been under-assessed, or assessed at a lower rate. The reopening was founded on turnover already disclosed in the assessee's balance sheet and amounted to a review of the original assessment on a mere change of opinion, which lay beyond Section 24(1). If revenue considered the assessment prejudicial, the proper course was to invoke revisional powers under Section 46. The reassessment proceedings were therefore without jurisdiction.

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Issues: Whether the reassessment proceedings initiated under Section 24(1) of the Delhi Sales Tax Act, 1975 were valid in law.

Analysis: Section 24(1) required the Assessing Authority to record reasons to believe, based on relevant material, that turnover had escaped assessment, been under-assessed, or been assessed at a lower rate before issuing notice. The record showed no such prior recording of reasons. The reopening was based on turnover already disclosed in the assessee's balance sheet and amounted to a review of the original assessment on a mere change of opinion. Such a course was beyond the scope of Section 24(1); if the assessment was thought to be prejudicial to revenue, recourse lay to revisional powers under Section 46 of the Delhi Sales Tax Act, 1975.

Conclusion: The reassessment proceedings were without jurisdiction and unsustainable in law, and the assessee succeeded.

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