Revisional jurisdiction may rely on later valuation material available at revision stage, supporting fresh assessment after incomplete valuation.

The Commissioner of Wealth-tax could invoke revisional jurisdiction under section 25(2) on the basis of valuation material received after the Wealth-tax Officer completed the assessment, because the revisional examination extends to the record available at the time of revision and is not confined to the material before the assessing officer when the order was passed. The assessment had been completed before the final valuation report under section 16A was received, but that later report could still support revision. The assessment was therefore set aside and fresh assessment directed, with the issue answered for the Revenue and against the assessee.

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Issues: Whether the Commissioner of Wealth-tax could invoke revisional jurisdiction under section 25(2) of the Wealth-tax Act, 1957 by relying on valuation material that had become available after the Wealth-tax Officer completed the assessment.

Analysis: The Wealth-tax Officer had referred the valuation of the assessee's properties under section 16A of the Wealth-tax Act, 1957 and completed the assessment before the final valuation report was received. The revisional order was made on the basis of that valuation report. The governing principle, as applied from the Supreme Court decision on the scope of revisional examination, is that the Commissioner is entitled to consider the record relating to the proceedings as available at the time of examination and is not confined to the material before the assessing officer when the assessment order was passed.

Conclusion: The Commissioner of Wealth-tax was justified in setting aside the assessment and directing fresh assessment, and the question was answered in favour of the Revenue and against the assessee.

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