Reassessment reasons, offshore trust assets and wealth-tax ownership rules shaped the outcome; jewellery issue was remanded.

Non-supply of the recorded reasons before requiring objections vitiated the reassessment, because the assessee was denied the statutory opportunity to contest the reopening. A return filed in response to section 17 notice could not be revised as if it were an original return under section 15, so the rejection of the revised return was upheld. Offshore immovable properties and foreign bank balances were not taxable as the assessee's wealth without proof that they were personal assets; trust and offshore entity structures could not be ignored merely because of beneficial-owner descriptions. The jewellery addition was not sustained in final form and the matter was remanded for fresh reconciliation of ownership and related family disclosures.

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Issues: Whether the reassessment was vitiated for non-supply of reasons recorded; whether the assessee could revise the return filed in response to notice under section 17; whether the additions relating to jewellery, offshore immovable properties and foreign bank balances were sustainable; and whether the jewellery issue required fresh reconciliation.

Issue (i): Whether the reassessment was vitiated for non-supply of reasons recorded.

Analysis: The assessee was entitled to receive the reasons recorded before being called upon to object. The reasons were admittedly never furnished, and the failure deprived the assessee of the opportunity to raise objections in the manner required by law.

Conclusion: The reassessment was held to be invalid, in favour of the assessee.

Issue (ii): Whether the assessee could revise the return filed in response to notice under section 17.

Analysis: A return filed in response to notice under section 17 is a return filed within the reassessment framework and, on the facts, the belated return could not be treated as a return filed under section 15 so as to permit revision in the same manner as an original return.

Conclusion: The rejection of the revised return was upheld, against the assessee.

Issue (iii): Whether the addition for jewellery was sustainable and whether the matter required fresh reconciliation.

Analysis: The jewellery issue involved reconciliation with jewellery reflected in the returns of family members and related entities. The record showed complexity in tracing ownership and the assessment had not properly resolved the reconciliation exercise, warranting another opportunity for factual verification.

Conclusion: The jewellery addition was not sustained in final form and the issue was remanded for fresh reconciliation, in favour of the assessee.

Issue (iv): Whether the offshore immovable properties could be taxed in the assessee's hands as wealth.

Analysis: The properties were held through an offshore discretionary trust structure with multiple beneficiaries. The right to appoint or remove trustees did not, by itself, convert trust property into the personal wealth of the beneficiary exercising that power. The trust remained an independent structure, and the corporate and trust entities could not be ignored merely on the basis of beneficial-owner descriptions used for compliance purposes.

Conclusion: The addition relating to offshore immovable properties was deleted, in favour of the assessee.

Issue (v): Whether the foreign bank balances held through offshore entities could be assessed as wealth of the assessee.

Analysis: Bank balances standing in the names of offshore companies and trust vehicles were not shown to be the assessee's personal assets. The definition of assets under the Wealth-tax Act did not justify treating offshore bank balances as cash in hand of the assessee, and the absence of evidence of legal ownership by the assessee was fatal to the addition.

Conclusion: The foreign bank balance addition was deleted, in favour of the assessee.

Final Conclusion: The assessee succeeded on the core jurisdictional challenge and on the major substantive additions relating to offshore assets and foreign bank balances, while the revised-return issue was decided against him and the jewellery issue was sent back for fresh factual examination.

Ratio Decidendi: Non-supply of recorded reasons vitiates reassessment, and assets held in an irrevocable discretionary trust or in offshore entities cannot be taxed in the hands of a beneficiary absent proof that they are the beneficiary's own wealth.

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