https://www.taxtmi.com/caselaws?id=168838 Constructive res judicata did not bar writ challenges to tax notices for later assessment periods because the earlier proceedings concerned different years and had not decided the new grounds on merits. The enhanced levy at 9 pies per ton was invalid because the statutory requirement of previous sanction under section 51(2) extended to rate increases, and the record did not show sanction for the enhancement; recovery could proceed only at the sanctioned rate, if otherwise lawful. Final assessments under the rules could not be reopened by later notices, since the scheme treated completed assessments as conclusive and contained no separate reopening power. The impugned demands therefore failed. en-us Mon, 24 Sep 1962 00:00:00 +0530 Tue, 31 Mar 2015 12:27:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168838 Constructive res judicata did not bar writ challenges to tax notices for later assessment periods because the earlier proceedings concerned different years and had not decided the new grounds on merits. The enhanced levy at 9 pies per ton was invalid because the statutory requirement of previous sanction under section 51(2) extended to rate increases, and the record did not show sanction for the enhancement; recovery could proceed only at the sanctioned rate, if otherwise lawful. Final assessments under the rules could not be reopened by later notices, since the scheme treated completed assessments as conclusive and contained no separate reopening power. The impugned demands therefore failed. Case-Laws Indian Laws Mon, 24 Sep 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168838