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    <title>2010 (4) TMI 974 - ALLAHABAD HIGH COURT</title>
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    <description>Section 3AB of the U.P. Trade Tax Act did not apply where the price of country liquor and the price of bottles or poly pouches were separately charged, because the exemption was confined to composite pricing of goods and packing material. Reassessment under section 21 required a rational basis for escaped assessment and could not rest on a mere change of opinion. On the earlier assessment years, the reopening was invalid because the issue had already been examined in the original assessments; for the later years, where no prior opinion had been formed, the notices were sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=164175</link>
      <description>Section 3AB of the U.P. Trade Tax Act did not apply where the price of country liquor and the price of bottles or poly pouches were separately charged, because the exemption was confined to composite pricing of goods and packing material. Reassessment under section 21 required a rational basis for escaped assessment and could not rest on a mere change of opinion. On the earlier assessment years, the reopening was invalid because the issue had already been examined in the original assessments; for the later years, where no prior opinion had been formed, the notices were sustained.</description>
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