1983 (1) TMI 164

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....5 and 17th February, 1977 respectively the WTO added "for the same reasons stated in the assessment order for the asst. yr. 1973-74" a sum of Rs. 24,048. The reasons given for the preceding assessment year were that considering the location in a posh locality the value was being enhanced. Later the WTO received an audit note informing him that the record revealed that for the preceding two asst. yrs.1972-73 and 1973-74 the assessee herself had returned the value of Rs. 3,22,682 and Rs. 3,31,962 respectively. It was further pointed out that while the value of the land has been taken at Rs. 16,000 per ground and the WTO had increased it by Rs. 4,000 per ground, the value of the building taken for this assessment year was not commensurate with....

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....brought to the notice of the WTO certain facts which were on record, it would only mean that the WTO was informed about the material already on record and required to reconsider the same material. It was submitted than the WTO could not by reappraising the same material come to a different conclusion in making a reassessment. Reliance was placed on the decision of the Supreme Court in CIT vs. Simson Carves Ltd. 1976 CTR (SC) 418 : (1976) 105 ITR 212 (SC). 4. On a consideration of the rival submission we are of the opinion that there are no merits in these appeals. It may be that the audit note reminded the WTO of only the fact that for the preceding assessment years the assessee had returned the value of the property at a higher figure. ....