COMMISSIONER OF WEALTH TAX Vs. HOOLAS DEVI

JUDGEMENT

(1.) THIS is a reference under Section 27(1) of the Wealth-tax Act, 1957 (for short "the Act" herein), at the instance of the Revenue for answering the following two questions of law, viz. :

(2.) THE facts necessary to be noticed for the disposal of this reference briefly stated are : that the assessee, Smt. Hoolas Devi, was assessed to wealth-tax for the assessment years 1965-66 to 1971-72 for different amounts of wealth pertaining to each assessment year. Those cases which were completed and finalised were reopened by the Wealth-tax Officer under Section 17(1)(a) of the Act on the following grounds :

(3.) IN CWT v. Arundhati Balkrishna [1970] 77 ITR 505, their Lordships of the Supreme Court have been pleased to observe as follows (at page 509):