https://www.taxtmi.com/caselaws?id=186833 Reassessment under the U.P. Trade Tax Act could be initiated only where the Assessing Authority had reason to believe, on relevant fresh material, that turnover had escaped assessment or deductions were wrongly allowed. A mere different view on the same facts already examined in the original assessment was insufficient. Because the reopening relied only on the Commissioner's circular and the same material previously considered, without any new facts or additional evidence, it amounted to a change of opinion and could not lawfully sustain reassessment. The reopening was therefore invalid. en-us Thu, 27 Nov 2014 00:00:00 +0530 Mon, 28 Jul 2025 11:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186833 Reassessment under the U.P. Trade Tax Act could be initiated only where the Assessing Authority had reason to believe, on relevant fresh material, that turnover had escaped assessment or deductions were wrongly allowed. A mere different view on the same facts already examined in the original assessment was insufficient. Because the reopening relied only on the Commissioner's circular and the same material previously considered, without any new facts or additional evidence, it amounted to a change of opinion and could not lawfully sustain reassessment. The reopening was therefore invalid. Case-Laws VAT / Sales Tax Thu, 27 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186833