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2016 (8) TMI 1373 - ALLAHABAD HIGH COURTReassessment of tax - Section 21 of U.P. Trade Tax Act, 1948 - Change of Opinion - assessment challenged on the ground that assessment was already finalized by Assessing Officer on 01.12.1998 and 24.07.2000 - Held that:- Learned Standing Counsel did 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.
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