1979 (8) TMI 51

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....i. The petitioner filed his wealth-tax, return for the assessment year 1968-69 on January 17, 1969. The 1/4th share of the immovable properties was valued at Rs. 1,55,000 and in support of this valuation an authorised valuation report dated January 25, 1969, was filed. The petitioner filed his wealth-tax return for the assessment year 1969-70 on November 16, 1969, and the properties were valued at Rs. 1,52,250. It is required to be stated that the valuation of properties for the assessment years 1966-67 and 1967-68 were less than what was valued for the subsequent years. The respondent No. 1, the WTO, considered the returns for four years, that is, from assessment years 1966-67 to 1969-70 together and the assessments were completed by an....

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....ut the impugned notices are not for these years but for the subsequent years. The respondent No. 1 states in the return in para. 16 that after the completion of the assessment for the relevant four years, the WTO secured information from the valuation report dated July 12, 1972, prepared by the Executive Engineer (Valuation) of the I.T. department, Bombay, that the properties were not properly valued by the petitioner and, therefore, escaped proper assessment. It is the claim of the respondents that the notices were served on the petitioner to reopen the assessment under s. 17(1)(b) of the W.T. Act, 1957. On behalf of the petitioner, it was contended, and in my judgment rightly, that the action of the respondents in threatening to re-ope....