Audit note alone cannot justify wealth-tax reassessment when no fresh information emerges for reopening.

Reassessment under section 17 of the Wealth-tax Act was invalid where it was initiated only on an audit note and no fresh information had come to the Wealth-tax Officer's notice. The reopening rested on the same material already examined in the original proceedings, including the asset valuation earlier determined by the Tribunal. A mere audit suggestion that a different method might produce a higher valuation did not constitute "information" for section 17(1)(b). Reassessment on the same material was therefore beyond the scope of the reopening power, and the reassessment orders were cancelled.

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Issues: Whether reassessments made under section 17 of the Wealth-tax Act, 1957 were valid when they were founded only on an audit note and no new information had come to the notice of the Wealth-tax Officer.

Analysis: The reassessments were reopened on the basis of the same material that had already been considered in the original proceedings, notwithstanding that the valuation of the assets had earlier been determined by the Tribunal on that very material. The audit party did not communicate any fresh information; it only suggested that a different method might result in a higher valuation. Such a suggestion did not amount to information for the purpose of section 17(1)(b), and a reopening on the same material was beyond the scope of reassessment proceedings.

Conclusion: The reassessments were invalid and the cancellation of the reassessment orders was .

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