( 1 ) THESE are two connected applications under Section 27 (3) of the Wealth-tax Act, 1957 (for short "the Act"), filed by the Commissioner of Wealth-tax, Agra, relating to the assessment years 1978-79 and 1979-80.

( 2 ) IN the wealth-tax assessments for the aforesaid two years, the assessing officer determined the fair market value of an immovable property described as "dehradun property" at Rs. 7,35,086 as on the two valuation dates relevant for the years in dispute. After the completion of those assessments, the Commissioner of Wealth-tax initiated proceedings under Section 25 (2) of the act, calling upon the assessee to show cause why the wealth-tax assessment orders for the years in dispute may not be cancelled, so as to be made afresh as the "dehradun property" had been undervalued by the assessing officer. It appears that, after the completion of the assessments, the assessing officer learnt that the property was sold by the assessee on August 18, 1983, for a consideration of Rs. 36 lakhs and this information prompted the Commissioner to take proceedings under Section 25 (2) of the Act.

( 3 ) AFTER considering the objections filed by the assessee, the Commi