2016 (8) TMI 1374

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..... .C., C.B. Tripathi ORDER 1. Heard Sri Piyush Agrawal, learned counsel for the petitioner and Sri C.B. Tripathi, learned Standing Counsel for respondents. 2. The order dated 24.06.2002 proposing re-assessment under Section 21 of U.P. Trade Tax Act, 1948 (hereinafter referred to as the "Act, 1948") and notice dated 20.08.2002 for Assessment Year 1996-97 have been challenged on the ground that ass .....

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..... of Court would not justify to invoke Section 21. Re-assessment under Section 21 is permissible only if there is a case of escape assessment and not on change of opinion. 4. 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, in our view, it is nothing but a case of change of opinion wh .....

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