https://www.taxtmi.com/caselaws?id=164204 Reassessment under section 21 of the U.P. Trade Tax Act, 1948 cannot be founded on the same material already examined in the original assessment merely because the assessing authority later adopts a different view; a valid reopening requires fresh, relevant material giving a rational basis to believe turnover has escaped assessment, and a mere change of opinion is impermissible. Approval under the proviso to section 21(2) requires jurisdictional satisfaction on the recorded reasons and the assessee's reply, but it cannot cure a reopening that is otherwise unsustainable for want of fresh material. The notices and reassessment proceedings were therefore held invalid. en-us Thu, 15 Apr 2010 00:00:00 +0530 Fri, 10 Oct 2014 17:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=164204 Reassessment under section 21 of the U.P. Trade Tax Act, 1948 cannot be founded on the same material already examined in the original assessment merely because the assessing authority later adopts a different view; a valid reopening requires fresh, relevant material giving a rational basis to believe turnover has escaped assessment, and a mere change of opinion is impermissible. Approval under the proviso to section 21(2) requires jurisdictional satisfaction on the recorded reasons and the assessee's reply, but it cannot cure a reopening that is otherwise unsustainable for want of fresh material. The notices and reassessment proceedings were therefore held invalid. Case-Laws VAT and Sales Tax Thu, 15 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=164204