No reassessment on basis of change of opinion without bringing any additional evidence during reasse

CST & VAT: U.P. VAT - Where Assessing Authority reopened assessment of assessee under section 21 of U.P. Trade Tax Act, since material in existence remained same during both assessment and reassessment proceedings and no additional material or facts had been referred to as per mandate of section 21(1), reassessment proceeding was merely based on change of opinion