person paying tax on compounded basis was not entitled, as per the statutory provisions, to avail input tax credit. By Ext.P1 series of notices issued to the petitioner on 10.05.2017, the respondents cited the non filing of applications for compounding by the petitioner as a reason to reopen the assessment for the years 2013-14 to 2016-17 and subject the turn over of the petitioner to assessment under the regular method in Section 6 (1)(f) of the Act. Although the petitioner preferred detailed replies to the said preassessment notices, the proposals were confirmed against the petitioner by Ext.P3 series of orders, whereby, demands of differential tax were raised against the petitioner. In the writ petition Ext.P3 series of orders is impugned, inter alia , on the ground that, while it would be inequitable on the part of the respondents to proceed against the petitioner seeking a demand of differential tax, solely on the ground that the petitioner had not preferred any compounding application for the assessment years in question, it is also contended that at any rate, the power to assess escaped turnover under Section 25 cannot be exercised on a mere change of opinion of the assessing officer, more so, when it was within the knowledge of department, that the petitioner was paying tax on compounded basis during the assessment years in
