CHEMICOS Vs. C S C

JUDGEMENT

(1.) Heard Sri R.R.Agrawal, learned Senior Counsel assisted by Sri Suyash Agrawal for the petitioner and Sri C.B.Tripathi, learned Special Counsel for the respondents.

(2.) This writ petition has been filed challenging the authorization order dated 22.3.2011 passed by the Additional Commissioner Grade-I, Commercial Tax, Sahranpur Zone, Saharanpur under the proviso to Section 21 (2) of the U.P. Trade Tax Act, 1948 (hereinafter referred to as the ''Act') for the Assessment Year 2004-05 and the notices dated 30.11.2011 issued by the Assessing Authority under Section 21 of the Act.

(3.) The submission of the learned counsel for the petitioner is that re-assessment proceedings initiated by the Assessing Authority is based on change of opinion which is impermissible and consequently the impugned order as well as the notice deserves to be quashed.