M/S. U.P. COOPERATIVE FEDERATION LIMITED LUCKNOW Vs. STATE OF U.P. THROUGH SECY. TAX AND REGISTRATION LKO. & ORS.

JUDGEMENT

(1.) Heard Sri J.N. Mathur, learned Senior Advocate assisted by Sri Mudit Agarwal, learned counsel for petitioner and learned Standing Counsel for respondents.

(2.) The writ petition is directed against notice issued under Section 21(2) of U.P. Trade Tax Act, 1948 (hereinafter referred to as the "Act, 1948") on the ground that respondents have got no material to show some tax has escaped assessment. Notice was issued to petitioner on 16.03.2012 and order has been passed granting permission for reopening of assessment on 26.03.2012.

(3.) Sri Mathur, learned Senior Advocate appearing for petitioner, submitted that there was no fresh material and, therefore, it is a case of change of opinion.