https://www.taxtmi.com/caselaws?id=152404 Reassessment under section 12(8) of the Orissa Sales Tax Act requires the authority's own recorded satisfaction, based on a factual basis and compliance with Rule 23 and Form VI. A reopening notice issued mechanically, without independent reasons, or under the dictate of an audit objection, is invalid because the authority cannot abdicate its discretion to the audit party. The use of the expression "for any reason" does not widen the power beyond the statutory "reason to believe" standard. The notice must also be preceded by formation and recording of satisfaction, and the statutory rules and prescribed form must be followed. en-us Tue, 04 Jul 2006 00:00:00 +0530 Mon, 04 Mar 2024 14:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=152404 Reassessment under section 12(8) of the Orissa Sales Tax Act requires the authority's own recorded satisfaction, based on a factual basis and compliance with Rule 23 and Form VI. A reopening notice issued mechanically, without independent reasons, or under the dictate of an audit objection, is invalid because the authority cannot abdicate its discretion to the audit party. The use of the expression "for any reason" does not widen the power beyond the statutory "reason to believe" standard. The notice must also be preceded by formation and recording of satisfaction, and the statutory rules and prescribed form must be followed. Case-Laws VAT and Sales Tax Tue, 04 Jul 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=152404