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    <title>1996 (7) TMI 521 - ALLAHABAD HIGH COURT</title>
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    <description>Reassessment or revision under the U.P. Sales Tax Act could not be sustained where the notices were based only on an earlier decision and not on any independent material showing escaped assessment. The Court held that jurisdiction to reopen assessment requires relevant material with a live nexus to the belief of escapement; a prior ruling rendered on different facts, especially where the dealer had produced distinguishing evidence, could not justify action by itself. On that basis, the notices and consequential proceedings were without jurisdiction, amounted to an impermissible change of opinion, and were quashed under article 226, though fresh action in accordance with law was left open if otherwise permissible.</description>
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      <title>1996 (7) TMI 521 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=158861</link>
      <description>Reassessment or revision under the U.P. Sales Tax Act could not be sustained where the notices were based only on an earlier decision and not on any independent material showing escaped assessment. The Court held that jurisdiction to reopen assessment requires relevant material with a live nexus to the belief of escapement; a prior ruling rendered on different facts, especially where the dealer had produced distinguishing evidence, could not justify action by itself. On that basis, the notices and consequential proceedings were without jurisdiction, amounted to an impermissible change of opinion, and were quashed under article 226, though fresh action in accordance with law was left open if otherwise permissible.</description>
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