Procedural valuation rules under the Wealth-tax Act applied to a pending appeal, requiring use of the amended Schedule III method.

Valuation rules under the Wealth-tax Act were treated as procedural, so the amended Schedule III method applied to pending assessments that had not attained finality. Because the assessment for 1984-85 was still in appeal, the property had to be valued under the amended valuation rule rather than the earlier method. The issue was therefore answered in favour of the assessee and against the Revenue.

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Issues: Whether Schedule III to the Wealth-tax Act, 1957 and the amended valuation rule applied to the valuation of immovable property for assessment year 1984-85 when the assessment was pending in appeal.

Analysis: The operative principle applied was that rules prescribing the method of valuation under the Wealth-tax Act are procedural in nature and therefore govern pending proceedings. On that basis, the amendment introducing Schedule III with effect from 1 April 1989 was held applicable to an assessment that had not attained finality and was still under appellate scrutiny. The property in question was therefore required to be valued under the amended valuation method rather than the earlier approach.

Conclusion: The question was answered in favour of the assessee and against the Revenue.

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