https://www.taxtmi.com/caselaws?id=155675 Section 21 of the U.P. Sales Tax Act permits reassessment only where the assessing authority has reason to believe, on relevant material, that turnover has escaped assessment or been under-assessed. That belief cannot rest on mere change of opinion, but it need not be founded solely on material outside the original record. Here, the Court found a substantial discrepancy between purchases shown in the trading account and purchase lists, supported by additional information received after the original assessment. Because the record did not show earlier consideration of that specific discrepancy, the reopening was not a second thought. The notice was therefore within jurisdiction, and judicial review under article 226 did not extend to testing the sufficiency of the material once some basis for belief existed. en-us Wed, 21 Dec 1988 00:00:00 +0530 Fri, 06 Sep 2013 15:30:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=155675 Section 21 of the U.P. Sales Tax Act permits reassessment only where the assessing authority has reason to believe, on relevant material, that turnover has escaped assessment or been under-assessed. That belief cannot rest on mere change of opinion, but it need not be founded solely on material outside the original record. Here, the Court found a substantial discrepancy between purchases shown in the trading account and purchase lists, supported by additional information received after the original assessment. Because the record did not show earlier consideration of that specific discrepancy, the reopening was not a second thought. The notice was therefore within jurisdiction, and judicial review under article 226 did not extend to testing the sufficiency of the material once some basis for belief existed. Case-Laws VAT and Sales Tax Wed, 21 Dec 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=155675