https://www.taxtmi.com/caselaws?id=164126 Sanction to reopen assessment under section 21(2) of the U.P. Trade Tax Act was held invalid where the authority granted permission mechanically, without considering the assessee's objections and without recording reasons. The court followed the principle that the assessee must be heard at the sanction stage and that the decision must reflect application of mind. Because the sanction order was non-speaking and arbitrary, the consequential reassessment notice could not survive and was set aside. Fresh consideration after hearing the assessee was directed. en-us Thu, 07 May 2009 00:00:00 +0530 Sun, 09 Nov 2014 21:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=164126 Sanction to reopen assessment under section 21(2) of the U.P. Trade Tax Act was held invalid where the authority granted permission mechanically, without considering the assessee's objections and without recording reasons. The court followed the principle that the assessee must be heard at the sanction stage and that the decision must reflect application of mind. Because the sanction order was non-speaking and arbitrary, the consequential reassessment notice could not survive and was set aside. Fresh consideration after hearing the assessee was directed. Case-Laws VAT and Sales Tax Thu, 07 May 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=164126