For asst. yr. 1979-80 , assessment was framed on 30th Jan., 1984 under s. 16(3) of WT Act, 1957. components of net wealth include (i) capital balance with firm M/s R. Kukreja and Co.; and (ii) debit balance with M/s Sham Lal and Co. ld. Authorised representative of assessee conceded before us that balance sheet of firms was not filed along with return of new wealth. assessee is partner in firm M/s D.R. Kukreja and Co. For asst. yr. 1980-81 assessment was framed under s. 16(1) of WT Act , 1957 and returned net wealth of Rs. 35,474 stood accepted. Assessment is made on 30th Jan., 1984 For this year also facts remain as for asst. yr. 1979-80 and so remains concession of ld. Authorised representative of assessee. In identically worded orders made under s. 25(2) of WT Act, 1957, assessments for both years were held to be erroneous insofar as these are pre-judicial to interest of Revenue, hence set aside with directions to WTO to make fresh assessment after proper examination and enquiry and in accordance with law and after affording adequate opportunity of being heard to assessee. assessee is aggrieved and so very naturally we have heard parties at length on two hearings viz. On 5th Jan., 1987 and 7th Jan., 1987. Assessee paper-books (12 pages and 10 pages ) have been duly noted. Orders of ld. Lower authorities have also been taken into account. We will dispose of these appeals with only reasoning that in our considered view these assessments are not in accordance with law, hence are erroneous insofar as these are pre-judicial to interest of Revenue inasmuch as apart from fact that these have not been made after due and proper enquiries, was but also that assessee, who is admittedly partner in firm, his interest therein in terms of his wealth has not been taken in accordance with s. 7 r/w statutory r. 2. Once assessments are not in accordance with and subject to provisions of Act, these are not only erroneous, but certainly are pre-judicial to interest of Revenue and we hold accordingly Gee Vee Enterprises vs. Addl. CIT 1975 CTR (Del) 61 (1975) 99 ITR 375 (Del) is pressed into service for desired fortification, but before parting, we like to deal with stand of assessee taken before us which can be summarised as under: (i) There has been no adequate opportunity of being heard to assessee at CIT level; (ii) There was no material with CIT to exercise jurisdiction under s. 25(2) of Act; (iii) Subsequent knowledge could not have been imported into and was not important for exercise of jurisdiction under s. 25(2) of Act; (iv) impugned orders of CIT for both years have been made beyond two years period, hence are barred by limitation. Before us assessee has pressed into services case laws reported as 52 ITR 516 at pages 528 and 522 (sic), CIT vs. Panna Devi Saraogi (1970) 78 ITR 728 at 740 (Cal), Ganga Properties vs. ITO (1979) 118 ITR 447 at 452 and 453 (Cal), CIT vs. Shantilal Agarwal (1983) 35 CTR (Pat) 304: (1983) 142 ITR 778 at 779 and 784 (Pat); and Sharbati Devi Jhalani vs. CWT & Ors. (1986) 54 CTR (Del) 85: (1985) 159 ITR 549 (Del). As regards first contention of assessee that there has been no opportunity of being heard, suffice it to say that paragraph 2 of impugned orders of CIT (in both orders) reads as under: "In response to show cause notice. Shri Suresh Virmani, F.C.A. attends on behalf of assessee. He is heard." In face of above and particularly in face of ld. Authorised representative's reply on query from Bench as to whether any adjournment was sought for at CIT level or not to which ld. Authorised representative was 'a categorical no': first grievance of assessee stands rejected. As regards absence of material with CIT sufficience it to say that charge of net wealth has to be on assessed net wealth and it has to be computed in accordance with and subject to provisions of Act and once assessments are not in accordance with law, no further material is required to hold that these are erroneous in so far as these are pre-judicial to interest of Revenue. This contention of assessee also fails. About subsequent knowledge and material as also 'record' and reliance of assessee on Ganga Properties vs. ITO (1979) 118 ITR 447 (Cal) suffice it to say that ld. Authorised representative only presumed things since in his opinion CIT acted on valuation report which was subsequent to framing of assessments, but he has no material with him to substantiate his stand. This contention was raised on assumptions and presumptions, hence does not call for any comments since these are not borne out from records or proceeding before ld. Lower authorities. Here also assessee fails. As regards impugned orders for both years being barred by limitation, this also fails in view of amendment brought by substitution w.e.f. 1st Oct., 1984 by Taxation Laws (Amendment) Act, 1984 in sub-s. (3) of s. 25 of WT Act. 1957 and after amendment said sub-section reads, "no order shall be made under sub-s (2)after expiry of two years from end of financial year in which order sought to be revised was passed." amendment is procedural in nature since it dells with procedure, pure and simple and it came into being as from 1st Oct., 1984 and impugned orders for both years have been made on 20th March, 1986 hence are within statutorily provided period of limitation. This contention of assessee also fails. In net result, impugned orders of ld. CIT/CWT made under s. 25(2) of WT Act, 1957 for both years stand upheld. appeals fail. *** MOHAN LAL v. WEALTH-TAX OFFICER