Reassessment cannot reopen completed wealth-tax items already included in the original assessment and finalised.

Reassessment under Section 17 of the Wealth-tax Act is confined to bringing to tax escaped net wealth and does not allow an assessee to reopen a completed assessment to seek exclusion of an item already included in the original computation. Where the assessment has attained finality, the reassessment stage cannot be used to advance a fresh claim omitted earlier, because that would enlarge the limited reassessment jurisdiction. On that reasoning, the authority had no jurisdiction to consider exclusion of the item at the reassessment stage, and the issue was decided against the assessee.

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Issues: Whether, in reassessment under Section 17 of the Wealth-tax Act, 1957, the Wealth-tax Officer could examine the assessee's claim for exclusion of an item already included in the original assessment.

Analysis: The reassessment jurisdiction under Section 17 is confined to bringing to tax escaped net wealth. Once an item has already been included in the original computation of net wealth and the assessment has attained finality, the reassessment stage does not permit the assessee to reopen that completed determination and seek exclusion of the same item. The Court followed the view taken by another High Court on the comparable reassessment scheme and held that the scope of reassessment cannot be enlarged to allow a fresh claim omitted at the original assessment stage.

Conclusion: The reassessment authority had no jurisdiction to consider the exclusion of the Rs. 5 lakhs item at the reassessment stage, and the question was answered against the assessee and in favour of the revenue.

Ratio Decidendi: Reassessment under Section 17 of the Wealth-tax Act, 1957 is confined to escaped net wealth and does not permit reopening of completed assessment items for the benefit of the assessee where the item was already included in the original assessment.

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