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    <description>Reassessment under Section 29(7) of the U.P. VAT Act was impermissible where the original assessment had already considered the relevant material and the reopening was based on a different view of the same facts. The refund issue had been examined earlier on material already before the assessing authority, so a later attempt to revisit it on a new interpretation amounted to a change of opinion. The impugned notice and approval were therefore not sustainable.</description>
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      <description>Reassessment under Section 29(7) of the U.P. VAT Act was impermissible where the original assessment had already considered the relevant material and the reopening was based on a different view of the same facts. The refund issue had been examined earlier on material already before the assessing authority, so a later attempt to revisit it on a new interpretation amounted to a change of opinion. The impugned notice and approval were therefore not sustainable.</description>
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