https://www.taxtmi.com/caselaws?id=155595 Reassessment under section 21 of the U.P. Sales Tax Act was treated as valid where the original assessment had granted exemption under section 4-B without addressing purchase-tax liability. The governing distinction was that a reopening is barred when the earlier order reflects a conscious view on the point, but it is permissible when the exemption was allowed through non-application of mind and escaped turnover is discovered later. The Tribunal's factual finding that the notification dated 1 June 1963 did not exempt purchases, and that the original allowance of exemption was not based on a considered view, was treated as binding. On that basis, the reassessment was upheld and the objection based on change of opinion failed. en-us Fri, 24 Feb 1989 00:00:00 +0530 Thu, 05 Sep 2013 16:33:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=155595 Reassessment under section 21 of the U.P. Sales Tax Act was treated as valid where the original assessment had granted exemption under section 4-B without addressing purchase-tax liability. The governing distinction was that a reopening is barred when the earlier order reflects a conscious view on the point, but it is permissible when the exemption was allowed through non-application of mind and escaped turnover is discovered later. The Tribunal's factual finding that the notification dated 1 June 1963 did not exempt purchases, and that the original allowance of exemption was not based on a considered view, was treated as binding. On that basis, the reassessment was upheld and the objection based on change of opinion failed. Case-Laws VAT and Sales Tax Fri, 24 Feb 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=155595