Revisional jurisdiction under Wealth-tax law allowed reliance on a later valuation report forming part of the record at examination.

In revisional proceedings under section 25(2) of the Wealth-tax Act, a valuation report received after assessment but available when the Commissioner examined the record was treated as part of the "record" under Explanation (b). Because the assessment had been completed without waiting for a report earlier called for, the Commissioner could consider that later-received report in deciding whether the assessment was prejudicial to the Revenue. The revisional power was therefore held to extend to reliance on the subsequent valuation material.

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Issues: Whether, in exercise of revisional powers under section 25(2) of the Wealth-tax Act, the Commissioner could take into account a valuation report received after the assessment but available in the record at the time of examination.

Analysis: The assessment had been completed without awaiting the valuation report that had earlier been called for. The report was received later and was part of the record when the Commissioner examined the assessment for prejudice to the Revenue. Explanation (b) to section 25(2) defined the record to include records relating to the proceeding at the time of examination by the Commissioner. The report, though subsequent to the assessment, had to be considered as part of that record.

Conclusion: The Commissioner was entitled to rely on the subsequent valuation report while exercising revisional jurisdiction, and the question was answered in favour of the Revenue and against the assessee.

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