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SUPREME COURT
, J
State – Appellant
Versus
M/s Aryaverth Udyog – Respondent
| Table of Content |
|---|
| 1. background and facts of the business of the respondent. (Para 1 , 2 , 3 , 4) |
| 2. impact of the circular on tax liabilities. (Para 5 , 6 , 7) |
| 3. writ petition filed against the reassessment notice. (Para 8 , 9) |
| 4. judicial examination of the high court's ruling. (Para 10 , 11 , 12) |
| 5. legal principles regarding reassessment threshold and limitations. (Para 15 , 16 , 30) |
1. These appeals are directed against the common judgment and order passed by the High Court of Judicature at Allahabad, Bench at Lucknow in Aryaverth Chawal Udyog v. State of U.P., 2008 (6) All LJ 338 : 2008 SCC Online All 579 dated 22-5-2008, whereby and whereunder, the High Court, while upholding the legality of Circular No. 137, dated 29-3-2007/30-3-2007 issued by the Commissioner of Trade Tax, has quashed the reassessment proceedings initiated under S.21 of the U.P. Trade Tax Act, 1948 (for short "the Act").
2. Since these appeals arise out of a common judgment and order of the High Court and factual matrix in all the appeals is also identical, while disposing of these appeals by this common judgment and order, we would only notice facts in the lead matter, Civil Appeal No. 6714 of 2009, in respect
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