M/S RAVI PRAKASH REFINERIES (P) LTD. vs STATE OF KARNATAKA

The Supreme Court ruled that the reopening of assessment under Section 12-A of the Karnataka Sales Tax Act, 1957, based solely on a change of opinion regarding the tax rate applicable to inter-State sales of Sunflower De-oiled Cake (SF DOC) was impermissible. The Court held that the earlier assessment, which taxed the sales at 2%, could not be revised to 4% without sufficient justification, thereby upholding the decision of the Karnataka Appellate Tribunal that set aside the reassessment order. The judgment reinforces the principle that a mere change of opinion does not warrant reopening assessments under tax law.