JUDGMENT

TULZAPURKAR, J.:— This appeal seeks to raise the following question of law for our determination :

Did the Appellate Assistant Commissioner of Wealth-tax have the power to rectify his predecessors order dated June 26, 1970 in view of the fact that there was no error apparent on the face of the record because the question as to whether the Amending Act applied to assessments which were already completed was a debatable question?

The High Court certified the question to be of general public importance which required a decision of this Court but in our view on the facts of case it is unnecessary to decide that question as the appeal could be disposed of briefly on the basis that the assessment in question could not be regarded as having become final or complete and therefore the postulate being absent the question does not arise.

2. The facts which are said to give rise to the question raised in the appeal are these. For the assessment year 1969-70 the respondent-assessee was assessed for wealth-tax purposes on the total wealth of Rs. 6,07,690/-, which included jewellery and ornaments of the value of Rs. 4,15,942 by an assessment order made by the Wealth-tax Officer on February