https://www.taxtmi.com/caselaws?id=236791 Reopening of assessment under Section 21(2) of the U.P. Trade Tax Act was held unsustainable where the original assessment had already examined the trade discounts, credit notes and refund entitlement. The sanction order did not record independent reasons, did not engage with the dealer's reply, and was unsupported by fresh material or any tangible basis. On that footing, the reopening was treated as mechanical and based on non-application of mind, and the consequential reassessment could not be sustained. The decision emphasises that reassessment cannot be used to revisit matters consciously considered in the original assessment on a mere change of opinion. en-us Fri, 13 Jan 2012 00:00:00 +0530 Wed, 24 Sep 2014 16:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236791 Reopening of assessment under Section 21(2) of the U.P. Trade Tax Act was held unsustainable where the original assessment had already examined the trade discounts, credit notes and refund entitlement. The sanction order did not record independent reasons, did not engage with the dealer's reply, and was unsupported by fresh material or any tangible basis. On that footing, the reopening was treated as mechanical and based on non-application of mind, and the consequential reassessment could not be sustained. The decision emphasises that reassessment cannot be used to revisit matters consciously considered in the original assessment on a mere change of opinion. Case-Laws VAT and Sales Tax Fri, 13 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236791