2016 (8) TMI 1373

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..... not dispute that re-assessment proceedings have been initiated only on the basis of subsequent judgment and not otherwise. That be so, it is nothing but a case of change of opinion which does not allow jurisdiction to initiate reassessment proceedings under Section 21 of Act, 1948. Petition allowed. - Writ Tax No. - 2233 of 2002 - - - Dated:- 31-8-2016 - Sudhir Agarwal And Dr. Kaushal Jayen .....

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..... ve issued impugned notice on the basis of a subsequent judgment of this Court in M/s U.P. Motors Pvt. Ltd. Vs. Assistant Commissioner, Trade Tax, Varanasi, 2000 UPTC 522 observing that concession or exemption granted by Assessing Officer was not correct. It is submitted that it is a case of change of opinion and not a case of escape assessment hence proceedings initiated under Section 21 of Act, .....

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