only dispute in this appeal relates to validity of re-opening of proceedings under s. 17 of WT Act. assessee is partner in M/s. Rajasthan Theatre s, fixed assets whereof were shown by firm at Rs. 35,102 as on December, 1969. This value was value as appearing in balance sheet, being WDV as per IT Act. In Appeal Nos. 642 to 645/79- 80, value of these assets was determined by AAC for years 1971-72 to 1974-75 at Rs. 10,50,390. WTO, therefore, added back 25 per cent of difference between two values at Rs. 6,99,369 being share of assessee in said firm which he computed at Rs. 1,74,842 under s. 17 of WT Act. said addition has been endorsed by AAC on appeal filed by assessee. assessee has consequently come up in second appeal before us. We have heard representatives of parties at length in this appeal. T h main point urged on behalf of assessee was that assessee had disclosed her capital in books of firm. She had also disclosed that she was partner in firm but she was not bound to disclose all assets held by t h e firm inasmuch as they were not necessary to determine her wealth-tax liability. Therefore, reopening of proceedings for computation of her n e t wealth was bad in law. number of authorities were cited for this proposition. After carefully considering all effects and circumstances of case, we are afraid, we are not inclined to accept this contention. perusal of form of return of wealth Annexure IV would show that apart from immovable property held by assessee, there is column meant for disclosing value of interest by assessee in firm or member of AOP or value of any other share in closely held company which are deemed to be urban assets under rr. 3 & 4 respectively by person submitting return. said column read as under: "Amount representing value of interest as partner in firm or as member of AOP or value of any shares in closely-held company deemed to be 'urban assets under rr. 3 & 4 respectively in paragraph B of Par I of Schedule to WT Act. This shows that even though any immovable property owned by firm of which assessee is partner, may not belong to assessee for purpose of relief under s. 5(1)(iv) of WT Act same has to be treated as part of assessee s wealth for purpose of levy of additional tax on urban wealth. Naturally if assessee is partner in firm which owns urban property assessee cannot be said to have disclosed fully and truly all material facts necessary for determination of her liability under WT Act. various authorities cited by assessee in this beheld, therefore, would not help assessee, for example, in Seth Satishkumar Modi vs. WTO (1980) 15 CTR (All) 340: (1983) 139 ITR 373 (All) that was decided was that valuation of shares adopted by assessee at cost price was in accordance with well recognised Principe of accountancy and net wealth of firm has to be calculated on principles of commercial accountancy. belief which WTO entertained that net wealth of assessee had escaped assessment was based on in relevant material and was arbitrary. In CWT (Guj) vs. Chatrashal Singhjoi D. Zala (1981) 25 CTR (Guj) 260: (1982) 135 ITR 826, (Guj) Valurer s report submitted by assessee for next year was held to be sufficient information for purpose of s. 17 (1) (b) of WT Act but mere fact that higher value was estimated for later year was insufficient to hold that assessee had concealed any particulars relating to its wealth. In present case, as we have pointed out above, there is clear column in return of wealth, according to which assessee is required to furnish particulars of immovable properties held by firm of which he was partner, and that information is relevant for purpose of determining additional tax on urban assets held by assessee inasmuch as these assets are liable to be added for purpose of computation under Schedule. Therefore, non- disclosure of such immovable property in return of wealth results in failure to furnish fully and truly all materiel facts for determination of wealth-tax liability of assessee. We, therefore, over-rule this objection. Another objection taken was that reasons were not recorded for reopening of these assessments. We are afraid WT Act does not require recording of reasons to be must before reopening of assessment. non-recording may be material if reasons do not exist. But if Court is satisfied that there were valid reasons for there opening of assessments, mere non-recording thereof will not be fatal. Another reason taken was that there were already proceedings reopening assessment pending and fresh proceedings could not be initiated during pendency of those proceedings. It was urged that before this reopening notice under s. 17 had been issued to assessee on 14th Sept. 1976. return was filed in pursuance thereof on 28th March 1977. re-assessment was made on 15th Feb. 1978 by which net wealth of assessee was revised from Rs. 6,18,317 to Rs. 6,75,566. This order was subject matter of appeal before AAC who decided same on 2nd Feb. 1980 and that order was served upon assessee on 8th Feb. 1980. present notice under s. 17 was issued on 30th March 1979. It was contended that procedings are continuation of original assessments. For that purpose, reliance was placed on decision of Supreme Court in CWT vs. Vimlaben Vadila (1983) 37 CTR (SC) 280: (1984) 145 ITR 11 (SC) again reference was made to S. P. Kochar vs. ITO (1983) 37 CTR (All) 49: (1984) 145 ITR 255 (All) and R. B. Seth Gujarmal Modi vs. CIT 1973 CTR (SC) 457: (1972) 84 ITR 261 (SC), Commercial Art Press vs. CIT Lucknow (1978) 115 ITR 876 (All) for proposition that once notice had been issued, and proceedings were pending, for re-assessment, fresh proceedings cannot be initiated. We have carefully gone though all these authorities. Some of authorities relating to imitation of proceeding under New Act. 1961 were proceedings for re-assessment under old Act of 1922 were pending. Some others are cases where original proceedings were pending before ITO and he also initiated fresh proceedings. It is obvious that if assessment was already reopened, there was no need of issuing notice under s. 147. Of course appeal proceedings are continuation of original proceedings, but in that sense, proceedings, before Tribunal or even reference proceedings before High Court or proceedings in Special Leave Petition for appeal before Supreme Court are continuation of original proceeding. Does representative of assessee wants us to held that if any wealth has escaped from assessment in original proceedings and for any reason appeal before Tribunal or reference before High Court or appeal by way of Special Leave is pending before Hon ble High Court, assessment cannot be reopened. This would lead to ridiculous situation. Such proposition at least is not acceptable to us. All decided cases are on special facts and circumstances of each case and do not lay down general proposition that there cannot be reopening because originally arrangement proceedings are somehow or other subject matter of dispute before any higher authority. CWT vs. Vimlaben Vadilal (1983) 37 CTR (SC) 280: (1984) 145 ITR 11 (SC) was not directly concerned with this question and in other authorities, appellate proceedings in retaliation to original reopening under relevant provision of law were not pending. We, are, therefore, not inclined to accept this ground. In result we are of opinion that there is no force in this appeal which is hereby dismissed. *** MR. UMA SANGHI v. WEALTH-TAX OFFICER