S.P.Goyal, J.

1. The following two questions of law have been referred to this court by the Income-tax Tribunal, Amritsar, at the instance of the revenue:

"(1) Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is right in law in holding that, there was no proper information available to the Income-tax Officer to proceed under Section 147(b) of the Income-tax Act, 1961 ?

(2) Whether, on the facts and in the circumstances of the case, the Tribunal is right in holding that the reopening of the assessments of the years 1970-71 and 1971-72 under Section 147(b) of the Income-tax Act, 1961, was invalid ?"

2. The assessment for the two years 1970-71 and 1971-72 was completed by the ITO on September 19, 1972, and the income assessed was "nil" for the first year and Rs. 6,493 for the second year. The wealth-tax assessments were completed on September 20, 1972. The wealth of the assessee consisted of deposits and one building at Maqbool Road, Amritsar, which was valued at Rs. 2,99,836, The assessee had purchased the plot of land for Rs. 71,516 for this building on January 21, 1969, started the construction on February 1, 1969, and completed the