Reassessment for escaped wealth needs fresh material; reopening based only on later valuation view was invalid.

Reassessment of wealth-tax requires a valid reason to believe that wealth escaped assessment, supported by subsequent material and not merely by a later view on valuation. Here, the Revenue sought to reopen the assessee's assessment on the basis that the firm's closing stock should have been valued at market value under rule 2B(2), increasing the assessee's share of wealth. The Tribunal found that the firm's assessment had already been completed before the assessee's original assessment and that no fresh information, later investigation, or other material was shown to justify reopening. In the absence of such material, the notice under section 17(1)(b) was invalid and reassessment could not proceed.

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Issues: Whether the notice issued under section 17(1)(b) of the Wealth-tax Act was validly founded on reason to believe that wealth had escaped assessment by applying rule 2B(2) to the valuation of the firm's closing stock.

Analysis: The revenue relied on the subsequent discovery that the closing stock of the firm should have been valued at market value under rule 2B(2) and that the assessee's share in the alleged difference had escaped assessment. The Tribunal found that the assessment of the firm had already been made before the assessee's original assessment, and no material was produced to show any later investigation, research, or fresh information coming to the WTO after the original assessment that could justify reopening. In the absence of such subsequent material, there was no basis to conclude that wealth had escaped assessment on the ground invoked for reassessment.

Conclusion: The reopening was held to be invalid, and the appeal by the revenue failed.

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