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    <title>2010 (3) TMI 1012 - ALLAHABAD HIGH COURT</title>
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    <description>Anhydrous ammonia kept in liquid form for commercial use was treated as a chemical under the common parlance test, and where competing entries were possible the beneficial entry was preferred in favour of the assessee. On reassessment, the court noted that action under section 21(2) of the U.P. Trade Tax Act required material with a nexus to escaped assessment; a mere change of opinion was insufficient. The text states that the original assessment had already applied mind to the commodity, and the later notification did not amount to fresh material. The reassessment sanction and consequential notice were therefore described as invalid.</description>
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      <description>Anhydrous ammonia kept in liquid form for commercial use was treated as a chemical under the common parlance test, and where competing entries were possible the beneficial entry was preferred in favour of the assessee. On reassessment, the court noted that action under section 21(2) of the U.P. Trade Tax Act required material with a nexus to escaped assessment; a mere change of opinion was insufficient. The text states that the original assessment had already applied mind to the commodity, and the later notification did not amount to fresh material. The reassessment sanction and consequential notice were therefore described as invalid.</description>
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