Reassessment on later valuation reports is invalid where reopening bypasses section 55A's limited valuation-reference power.

A concluded assessment cannot be reopened under section 148 of the Income-tax Act, 1961 on the basis of a valuation report obtained otherwise than in accordance with section 55A. The Assessing Officer's authority to seek valuation is limited to the situations expressly permitted by section 55A, and the general enquiry powers under sections 131(1), 133(6) and 142(2) do not extend to a reference to a Valuation Officer for reopening purposes. On that basis, the reassessment notices were held to be without jurisdiction and were quashed.

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Issues: Whether reassessment notices under section 148 of the Income-tax Act, 1961 could be issued on the basis of a valuation report obtained after completion of the original assessments, without a reference under section 55A of the Income-tax Act, 1961.

Analysis: The controlling principle was that the Assessing Officer's power to obtain a valuation report from a Valuation Officer is confined to the circumstances specifically provided in section 55A of the Income-tax Act, 1961. The general powers of enquiry under sections 131(1), 133(6) and 142(2) of the Income-tax Act, 1961 do not authorise a reference to the Valuation Officer for other purposes. Once the assessments had been completed, the subsequent valuation report could not be used as a jurisdictional basis to reopen concluded assessments under section 148 of the Income-tax Act, 1961.

Conclusion: The reassessment notices were without jurisdiction and could not be sustained.

Final Conclusion: The writ petition was allowed and the impugned reassessment notices were quashed.

Ratio Decidendi: The Assessing Officer cannot reopen a concluded assessment under section 148 of the Income-tax Act, 1961 on the basis of a valuation report obtained otherwise than in accordance with section 55A of that Act, and the general powers of enquiry do not expand that limited authority.

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