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    <title>2011 (3) TMI 1527 - ALLAHABAD HIGH COURT</title>
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    <description>Reassessment under section 21 of the U.P. Trade Tax Act was not barred by change of opinion where the original assessment had not contained a real adjudication on the nature of the transactions. The court noted that the assessing authority had not meaningfully examined the assessee&#039;s stock transfer claim under section 6A of the Central Sales Tax Act, and the reassessment proposal was based on the view that SIM cards and smart cards had been transferred to different companies and turnover had escaped assessment. On that basis, the approval for reassessment and the consequential notice were upheld.</description>
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    <pubDate>Thu, 03 Mar 2011 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=165769</link>
      <description>Reassessment under section 21 of the U.P. Trade Tax Act was not barred by change of opinion where the original assessment had not contained a real adjudication on the nature of the transactions. The court noted that the assessing authority had not meaningfully examined the assessee&#039;s stock transfer claim under section 6A of the Central Sales Tax Act, and the reassessment proposal was based on the view that SIM cards and smart cards had been transferred to different companies and turnover had escaped assessment. On that basis, the approval for reassessment and the consequential notice were upheld.</description>
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