https://www.taxtmi.com/caselaws?id=159285 Reassessment under section 21 of the U.P. Trade Tax Act cannot proceed on a mere change of opinion where the material relied upon was already before the assessing authority in the original assessment. The record showed that the survey material had been available earlier and no fresh material was disclosed to support reopening. In these circumstances, the reassessment notice was outside the scope of reassessment jurisdiction, as a different inference from the same material does not amount to escaped assessment. The notices were therefore without authority of law and liable to be quashed. en-us Mon, 15 Jul 1996 00:00:00 +0530 Tue, 19 Nov 2013 17:14:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=159285 Reassessment under section 21 of the U.P. Trade Tax Act cannot proceed on a mere change of opinion where the material relied upon was already before the assessing authority in the original assessment. The record showed that the survey material had been available earlier and no fresh material was disclosed to support reopening. In these circumstances, the reassessment notice was outside the scope of reassessment jurisdiction, as a different inference from the same material does not amount to escaped assessment. The notices were therefore without authority of law and liable to be quashed. Case-Laws VAT and Sales Tax Mon, 15 Jul 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=159285