https://www.taxtmi.com/caselaws?id=161936 Reassessment under section 24 of the Delhi Sales Tax Act, 1975 cannot be sustained on a mere change of opinion. The Commissioner must have reason to believe that turnover escaped assessment, was under-assessed, or that a deduction was wrongly made, and that belief must rest on fresh material, new information, or a relevant change in law. Where the reopening is based only on a notification already in existence at the time of the original assessments, it amounts to a fresh application of mind to the same facts. The revisional remedy under section 46 confirms that reassessment cannot be used as a disguised review, so the reopening was invalid and the reassessment orders were quashed. en-us Sat, 20 Nov 2004 00:00:00 +0530 Tue, 11 Feb 2014 16:10:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=161936 Reassessment under section 24 of the Delhi Sales Tax Act, 1975 cannot be sustained on a mere change of opinion. The Commissioner must have reason to believe that turnover escaped assessment, was under-assessed, or that a deduction was wrongly made, and that belief must rest on fresh material, new information, or a relevant change in law. Where the reopening is based only on a notification already in existence at the time of the original assessments, it amounts to a fresh application of mind to the same facts. The revisional remedy under section 46 confirms that reassessment cannot be used as a disguised review, so the reopening was invalid and the reassessment orders were quashed. Case-Laws VAT and Sales Tax Sat, 20 Nov 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=161936