https://www.taxtmi.com/caselaws?id=245500 Amended limitation for reassessment under section 21(2) of the U.P. Trade Tax Act, 1948 was treated as retrospective because the statutory language was explicit and was applied to pending and earlier assessments within the enlarged period. The reassessment notice was also sustained because it rested on relevant material showing discrepancy in exemption claimed against the certificates relied upon, creating a rational basis to believe that income had escaped assessment. The Court distinguished a mere change of opinion on the same facts from reassessment founded on tangible material, and held that the proceedings were not invalid on either ground. en-us Mon, 03 Mar 2014 00:00:00 +0530 Thu, 23 Jul 2015 16:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=245500 Amended limitation for reassessment under section 21(2) of the U.P. Trade Tax Act, 1948 was treated as retrospective because the statutory language was explicit and was applied to pending and earlier assessments within the enlarged period. The reassessment notice was also sustained because it rested on relevant material showing discrepancy in exemption claimed against the certificates relied upon, creating a rational basis to believe that income had escaped assessment. The Court distinguished a mere change of opinion on the same facts from reassessment founded on tangible material, and held that the proceedings were not invalid on either ground. Case-Laws VAT and Sales Tax Mon, 03 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=245500