https://www.taxtmi.com/caselaws?id=187060 Reassessment under Section 21 of the U.P. Trade Tax Act, 1948 cannot rest merely on a change of opinion, and reopening on that basis is impermissible. The Court also treated the departmental circular as binding on tax authorities and held that it required an effective opportunity of hearing before passing a reassessment order; failure to do so amounted to breach of natural justice. The text further notes that, despite the reassessment being found unsustainable on merits, the writ was not finally decided against the remand order because the assessment order had merged in the appellate order. en-us Thu, 25 Feb 1999 00:00:00 +0530 Fri, 07 Oct 2016 17:13:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=187060 Reassessment under Section 21 of the U.P. Trade Tax Act, 1948 cannot rest merely on a change of opinion, and reopening on that basis is impermissible. The Court also treated the departmental circular as binding on tax authorities and held that it required an effective opportunity of hearing before passing a reassessment order; failure to do so amounted to breach of natural justice. The text further notes that, despite the reassessment being found unsustainable on merits, the writ was not finally decided against the remand order because the assessment order had merged in the appellate order. Case-Laws VAT and Sales Tax Thu, 25 Feb 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=187060