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    <description>Reassessment under section 21 of the U.P. Sales Tax Act was held valid where material already on record showed a possible lower-rate taxation issue and the regular assessment order did not evidence any conscious decision on the applicable rate, so the proceedings were not a prohibited change of opinion. On classification, spent bleaching earth was held not to retain the character of a mineral after repeated use in oil refining, because it had lost its original absorptive property and become a materially altered commercial residue. It was therefore taxable as an unclassified commodity at the higher rate.</description>
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