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Issues:
Validity of reassessment under section 17(1)(b) of the Wealth-tax Act after reopening under section 17(1)(a). Analysis: The case involved two references under section 27(1) of the Wealth-tax Act, 1957, concerning reassessment validity under sections 17(1)(a) and 17(1)(b) of the Act. The assessee's wealth was initially determined without a valuation report for a building called "Harsha Mahal." Subsequently, an official valuer's report valued the building higher. The Tribunal held that reassessment under section 17(1)(b) was valid as a portion of the wealth had escaped assessment due to new information. The Appellate Assistant Commissioner's view that the valuation report was not binding and constituted a mere change of opinion was overturned by the Tribunal. The assessee contended that the subsequent valuation report was not binding as the original assessment was not based on it. Citing a Supreme Court decision, the assessee argued that a mere change of opinion could not justify reassessment under section 17 of the Act. The Revenue argued that the valuation report constituted new information for reassessment under section 17(1)(b) of the Act. They relied on precedents where valuation reports were considered binding and constituted valid information for reassessment. The court considered the legal precedents cited by both parties. It noted that the valuation report received after the original assessment could be considered new information for reassessment under section 17(1)(b) of the Act. Relying on previous judgments, the court held that the reassessment under section 17(1)(b) was valid as it was based on information that had not been previously considered. The court ruled in favor of the Revenue, upholding the validity of the reassessment under section 17(1)(b) of the Wealth-tax Act. In conclusion, the court answered the question referred for its opinion in the affirmative, supporting the validity of the reassessment under section 17(1)(b) of the Wealth-tax Act. The judgment clarified the distinction between new information justifying reassessment and a mere change of opinion, emphasizing the importance of valid information for reassessment purposes under the Act.
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