https://www.taxtmi.com/caselaws?id=155475 A legal objection challenging the validity of reassessment proceedings may be raised before the Tribunal where it was not decided at the earlier appellate stage, and the Tribunal must adjudicate it on merits after hearing both sides. The assessee had raised a challenge to initiation under section 21 of the U.P. Sales Tax Act, 1948, but that contention remained undecided by the first appellate authority. The record did not show that the point had not been urged earlier, and the appeal ground reflected a challenge based on mere change of opinion. en-us Mon, 23 Feb 1987 00:00:00 +0530 Wed, 04 Sep 2013 16:28:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=155475 A legal objection challenging the validity of reassessment proceedings may be raised before the Tribunal where it was not decided at the earlier appellate stage, and the Tribunal must adjudicate it on merits after hearing both sides. The assessee had raised a challenge to initiation under section 21 of the U.P. Sales Tax Act, 1948, but that contention remained undecided by the first appellate authority. The record did not show that the point had not been urged earlier, and the appeal ground reflected a challenge based on mere change of opinion. Case-Laws VAT and Sales Tax Mon, 23 Feb 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=155475