Assessments in such cases should be reopened u/s.17(1)(b).

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....arding reopening of earlier years assessments in the light of a valuer's certificate since filed by the assessee for a later year, were issued. 2. The matter has been reconsidered and the following instructions are issued in suppression of those contained in the said circular.: (a) Where the assessee files his wealth-tax return for the first time on the basis of a valuer's certificate disclo....

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....aluer for any later year since filed by the assessee exceeds that adopted in the wealth-tax assessments for the earlier years, the difference having arisen on account of a different basis of valuation adopted by the valuer, and such a difference exceeds 25% of the value adopted for the earlier years, the WTOs should examine whether or not the assessee can plausibly explain the variation in value. ....