(i) It is not open to the WTO u/s 16A of the W. T. Act to call for the report of the Valuation Officer after the assessment proceedings are completed and use that report to commence proceedings for reassessment. The jurisdiction conferred on the WTO is limited to calling for the report when the proceeding are pending and not when the Wealth Tax Officer becomes functious officio.

(ii) A report of the DVO called for after the assessment proceedings is without jurisdiction and consequently a nullity. Such report cannot give “reason to believe” to reopen the assessment u/s 17.

(iii) The position in law in so far as a report which was called for but not received during the pendency of the proceedings but received subsequent to the proceeding will have to be treated differently. The fact that the assessment has been completed is not a bar to considering the DVO’s report and to be used as the basis for reopening the assessment.