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    <title>2014 (4) TMI 954 - ALLAHABAD HIGH COURT</title>
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    <description>Rectification under Section 22 of the U.P. Sales Tax Act, 1948 is limited to a mistake apparent on the face of the record. A considered assessment order does not become erroneous merely because a later judgment adopts a different view on taxability. A subsequent judicial pronouncement cannot, by itself, transform a conscious assessment into an apparent error, particularly where no binding authority was ignored when the assessment was made. On that basis, use of the later judgment to reopen the assessment was held to be beyond the scope of Section 22 and outside the Assessing Authority&#039;s jurisdiction.</description>
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      <description>Rectification under Section 22 of the U.P. Sales Tax Act, 1948 is limited to a mistake apparent on the face of the record. A considered assessment order does not become erroneous merely because a later judgment adopts a different view on taxability. A subsequent judicial pronouncement cannot, by itself, transform a conscious assessment into an apparent error, particularly where no binding authority was ignored when the assessment was made. On that basis, use of the later judgment to reopen the assessment was held to be beyond the scope of Section 22 and outside the Assessing Authority&#039;s jurisdiction.</description>
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