https://www.taxtmi.com/caselaws?id=403708 Reassessment is valid only where the assessing authority first records a bona fide reason to believe, based on relevant material, that turnover has escaped assessment under the correct statute. That belief must have a rational nexus with the record and cannot rest on extraneous or mistaken premises. Where the original assessment does not show a formed opinion, a change-of-opinion objection may not succeed; however, the reopening still fails if the recorded basis is factually incorrect or unsupported by independent material. The text states that a notice founded on proceedings under a different statutory regime was extraneous and insufficient to confer jurisdiction. en-us Wed, 03 Feb 2021 00:00:00 +0530 Wed, 07 Jul 2021 09:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=403708 Reassessment is valid only where the assessing authority first records a bona fide reason to believe, based on relevant material, that turnover has escaped assessment under the correct statute. That belief must have a rational nexus with the record and cannot rest on extraneous or mistaken premises. Where the original assessment does not show a formed opinion, a change-of-opinion objection may not succeed; however, the reopening still fails if the recorded basis is factually incorrect or unsupported by independent material. The text states that a notice founded on proceedings under a different statutory regime was extraneous and insufficient to confer jurisdiction. Case-Laws VAT and Sales Tax Wed, 03 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=403708