ORDER
The Court
1. On the question of valuation, the Tribunal has held that there was no material to justify reopening of assessment under ss. 17(1)(a) and 17(1)(b) of the Act. The question involved is a question of fact and therefore, we cannot interfere with the conclusion of the Tribunal. So far as the amounts outstanding are concerned, ld. counsel for the department submits that petitions under s. 256(2) in respect of income-tax assessments have been rejected by this Court. In these circumstances, these applications are dismissed.
2. Learned counsel for the Department submitted that the reopening of the assessments under s. 17 of the Act was based on a report of the Valuation Officer under s. 16A obtained by the WTO after the original assessments were completed. The Tribunal following a decision of the Calcutta High Court held that the WTO, after completing the assessment, has no jurisdiction to call for the report of the Valuation Officer under s. 16A of the Act. He submits that this is a question of law. We do not express any opinion on this. But even assuming that the Valuation report was properly obtained that cannot justify the reopening of the assessment on the question of valuation which had been determined on proper principles earlier. This question is, therefore, refused and these applications are disposed of. No order as to costs.