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1978 (10) TMI 141 - HC - VAT and Sales TaxExtract: .......S.C.)., it must be held that the proceedings under section 21 of the Act cannot be initiated on a mere change of opinion on the part of the Sales Tax Officer. The first question is answered in the affirmative and the second question in the negative. The assessee is entitled to its costs, which is assessed at Rs. 200. Reference answered accordingly.
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