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    <title>2017 (11) TMI 1501 - ALLAHABAD HIGH COURT</title>
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    <description>Reassessment under Section 21 must remain confined to the material that formed the original reason to believe and to the grounds covered by the sanction and notice. The assessing authority cannot enlarge the reassessment into a de novo exercise by introducing new issues or fresh material after initiation. On these facts, the item of turnover known as SSF was neither included in the recorded basis for reassessment nor mentioned in the show cause notice, so its assessment in reassessment proceedings was without jurisdiction. A later liberty to issue a fresh notice could not cure that foundational defect.</description>
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      <description>Reassessment under Section 21 must remain confined to the material that formed the original reason to believe and to the grounds covered by the sanction and notice. The assessing authority cannot enlarge the reassessment into a de novo exercise by introducing new issues or fresh material after initiation. On these facts, the item of turnover known as SSF was neither included in the recorded basis for reassessment nor mentioned in the show cause notice, so its assessment in reassessment proceedings was without jurisdiction. A later liberty to issue a fresh notice could not cure that foundational defect.</description>
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