Reassessment based on already available valuation material was invalid, as no subsequent information supported reopening under wealth-tax law.

Reassessment under section 17(1)(b) of the Wealth-tax Act, 1957 was held invalid where the reopening was based on a firm's assessment order and alleged undervaluation of closing stock under rule 2B(2) of the Wealth-tax Rules, 1957. The relevant material on the firm's closing stock valuation, gross profit rate, and valuation method was already before the common assessing authority when the assessee's original assessment was made, and no fresh or subsequent information from later enquiry or investigation was shown. On those facts, the Tribunal treated the material as not constituting subsequent information, so the reopening failed.

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Issues: Whether reassessment under section 17(1)(b) of the Wealth-tax Act, 1957 was validly initiated on the basis of the firm's assessment order and the alleged undervaluation of closing stock under rule 2B(2) of the Wealth-tax Rules, 1957.

Analysis: The reopening was founded on the assessment order of the firm in which the assessee was a partner, but that order had already been made before the assessee's original assessment. The material relating to the valuation of the firm's closing stock, its gross profit rate, and the method of valuation was already before the common assessing authority. No fresh or subsequent information was shown to have been gathered later through further enquiry or investigation. In identical facts, the Tribunal had earlier held that such material did not constitute subsequent information within the meaning of section 17(1)(b).

Conclusion: The reassessment proceedings were invalidly initiated and the reopening of the assessee's assessment failed.

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