Change of opinion on share valuation cannot justify reopening completed wealth-tax assessments without new material.

Reopening of completed wealth-tax assessments under section 17 was impermissible where the assessee had disclosed all relevant facts on share valuation and the Wealth-tax Officer had already accepted that valuation. A later attempt to reassess the same shares on the basis of a proposed revaluation amounted only to a change of opinion on the method of valuation, and no new material was shown to justify jurisdiction. The notice under section 17 therefore lacked legal foundation and was invalid.

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Issues: Whether the notice issued under section 17 of the Wealth-tax Act, 1957 for reopening the completed wealth-tax assessments was valid when the reopening was ed on a proposed revaluation of shares and no new material was shown to justify the exercise of jurisdiction.

Analysis: The assessments had been completed after the assessee disclosed all relevant facts regarding the valuation of the shares and the Wealth-tax Officer had accepted that valuation. The subsequent attempt to reopen the assessments was founded only on a later view that the shares had been undervalued. Such a mere change of opinion on the method of valuation does not furnish jurisdiction to reopen completed assessments under section 17. The notice, therefore, lacked legal foundation.

Conclusion: The notice under section 17 was invalid and was liable to be struck down. The decision is in favour of the assessee.

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