https://www.taxtmi.com/caselaws?id=233700 Sanction under the proviso to Section 21(2) of the U.P. Trade Tax Act for reopening completed assessments is a limited satisfaction-based jurisdiction, not an adjudicatory exercise. The authority must have relevant prima facie material indicating escaped turnover and must apply its mind to that material; the adequacy of the evidence is not open to judicial review at the sanction stage. Here, the sanctioning authority considered search material, seized hard-disk data, directors' statements, and the petitioners' reply before granting permission, so the reopening was not invalid for want of material. The sanction and consequential reassessment notice were upheld, and the writ challenge failed. en-us Wed, 08 May 2013 00:00:00 +0530 Wed, 16 Jul 2014 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233700 Sanction under the proviso to Section 21(2) of the U.P. Trade Tax Act for reopening completed assessments is a limited satisfaction-based jurisdiction, not an adjudicatory exercise. The authority must have relevant prima facie material indicating escaped turnover and must apply its mind to that material; the adequacy of the evidence is not open to judicial review at the sanction stage. Here, the sanctioning authority considered search material, seized hard-disk data, directors' statements, and the petitioners' reply before granting permission, so the reopening was not invalid for want of material. The sanction and consequential reassessment notice were upheld, and the writ challenge failed. Case-Laws VAT and Sales Tax Wed, 08 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233700