Regarding assessment under Bihar VAT

Dear Sir/Mam, A notice has been served for assessment under section 31 of Bihar VAT Act for F. Y. 2014-15 & 2015-16 to a dealer. But there is no any assessment or audit (departmental/CAG) has been conducted for the same years. As I have read a notice for assessment under section 31 serve if any audit or regular assessment has done for the same financial year previously and the Tax Authorities have reason to belief that there are a chance of under figured the sales amout to reduce the tax liability, Have availed worng ITC etc. Your valuable opinion will be highly appreciable and would enhance my knowledge on the above mentioned subject.