Section 56 of the U.P. VAT Act would reveal that the section has wide power, but seeking of permission by the assessing authority for making reassessment of the dealer is not conferred under the said provision.
Learned counsel for the petitioner has vehemently urged that the royalty payment is tax and not consideration in the context of the privilege parted by the State allowing the petitioner and others to mine sand. That being the nature of the payment made by the petitioner, the same is not amenable to GST as it is not consideration either for sale of goods or service provided.
