Wealth-tax reassessment valid where HUF declaration on prescribed wealth was found incorrect and section 17(1)(a) applied.

Section 17(1)(a) of the Wealth-tax Act applied where the assessee's return declared that no member of the Hindu undivided family owned wealth of the prescribed amount, but the assessing authority later found assessable wealth existed. The declaration did not bar reassessment, because the lower-rate condition required verification of the members' wealth position and could be reopened when that foundation proved incorrect. The Court applied the same reasoning it had earlier used on a comparable Income-tax Act rate issue and upheld the reopening as within jurisdiction, in favour of the Revenue.

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Issues: Whether section 17(1)(a) of the Wealth-tax Act, 1957 was attracted to the assessee's case and whether the reopening of the wealth-tax assessment was without jurisdiction.

Analysis: The declaration filed with the original return that no member of the Hindu undivided family had wealth of Rs. 1,00,000 or more did not preclude reassessment when the assessing authority found that the family did have assessable wealth. The provision governing the lower rate required verification that no member of the Hindu undivided family possessed wealth of the prescribed amount. The reasoning earlier applied by the Court to a similar tax-rate question under the Income-tax Act was held equally applicable to the Wealth-tax Act.

Conclusion: Section 17(1)(a) was held to be applicable, and the reopening of the assessment was upheld as valid, against the assessee and in favour of the Revenue.

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