Distinct reassessment proceedings under the Wealth-tax Act were upheld despite a stayed rectification challenge, with jurisdiction confirmed.

Proceedings under section 17 of the Wealth-tax Act and proceedings under section 25(2) were treated as distinct, one for reassessment and the other for rectification. The pendency and stay of the section 25(2) proceedings did not bar initiation of section 17 action, and the Wealth-tax Officer had jurisdiction to issue the notice. The challenge to the notice therefore failed, and mandamus was refused.

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Issues: Whether a notice issued under section 17 of the Wealth-tax Act could be challenged on the ground that proceedings under section 25(2) of the same Act were already under challenge and stayed, and whether the Wealth-tax Officer lacked jurisdiction to issue the section 17 notice.

Analysis: The proceedings under section 17 and section 25(2) were treated as distinct and separate, one relating to reassessment and the other to rectification. The pendency and stay of proceedings under section 25(2) did not bar initiation of proceedings under section 17. The Wealth-tax Officer was held to have ample jurisdiction to issue the impugned notice.

Conclusion: The notice under section 17 was not invalid on the grounds urged, and the request for mandamus was rejected.

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