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Issues Involved:
1. Jurisdiction of reassessment notices under section 17 of the Wealth-tax Act. 2. Validity of reassessment based on valuation reports received post original assessment. 3. Maintainability of writ petitions challenging reassessment notices. Issue-wise Detailed Analysis: 1. Jurisdiction of Reassessment Notices: The primary issue is whether the reassessment notices issued under section 17 of the Wealth-tax Act for the assessment years 1985-86 to 1988-89 were within the jurisdiction of the assessing authority. The petitioner contended that the reassessment notices were without jurisdiction as the original assessments had been completed based on full and true disclosures of all material facts. The court examined the amended section 17 of the Act, which allows reassessment if the Assessing Officer has "reason to believe" that the net wealth chargeable to tax has escaped assessment due to underassessment or other reasons. The court emphasized that the key phrase "reason to believe" must be based on specific, reliable, and relevant information that comes to the Assessing Officer's possession subsequently. 2. Validity of Reassessment Based on Valuation Reports: The reassessment notices were issued based on a valuation report received after the original assessments were completed. The court noted significant differences between the initial assessed values and the values in the valuation report for properties like Karni Bhawan, Junagarh Fort, and Gajner Palace. The petitioner argued that since the Department did not accept the valuation declared by the assessee and completed the assessments based on the Settlement Commission's order, the reassessment could not be justified. However, the court held that the Assessing Officer's decision to seek a valuer's report during the pendency of the assessment proceedings indicated dissatisfaction with the disclosed values. Therefore, the subsequent receipt of the valuation report provided a valid basis for reopening the assessments under section 17. 3. Maintainability of Writ Petitions: The court addressed the preliminary objection raised by the Revenue regarding the maintainability of the writ petitions under Article 226 of the Constitution. It was argued that since the reassessment notices were not without jurisdiction, the petitioner should pursue statutory remedies, including appeals, instead of filing writ petitions. The court agreed with this contention, emphasizing that the petitioner could raise all objections before the Assessing Officer and, if necessary, appeal against any adverse orders. Consequently, the court dismissed the writ petitions as not maintainable, directing the petitioner to participate in the departmental proceedings and avail statutory remedies. Conclusion: The court concluded that the reassessment notices were within jurisdiction, justified by the receipt of the valuation report during the pendency of the original assessments. The writ petitions challenging these notices were dismissed as not maintainable, and the petitioner was directed to follow statutory procedures for any grievances. The judgment underscored the importance of "reason to believe" in reassessment proceedings and the necessity for taxpayers to utilize statutory remedies before approaching the judiciary.
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