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Issues: Whether the assessee's mere right to receive enhanced compensation and interest in respect of acquired land constituted an asset includible in net wealth under the Wealth-tax Act, 1957 for the relevant assessment years.
Analysis: The land was acquired under the Land Acquisition Act, 1894 and the enhanced compensation remained under challenge in appellate proceedings when the relevant wealth-tax assessments were made. The Court held that, under the unamended definition of assets in section 2(e) of the Wealth-tax Act, 1957, a mere right to receive compensation was not an absolute or present asset where the amount remained uncertain and contingent on the outcome of pending proceedings. The authorities relied upon by the Revenue, concerning different statutory schemes, were held inapplicable. The Court applied the principle that a right which is dependent on the result of litigation and may be defeated altogether is only an inchoate and speculative right, not wealth in praesenti.
Conclusion: The right to receive enhanced compensation and interest was not includible in the assessee's net wealth for the relevant assessment years and the question was answered against the Revenue.
Ratio Decidendi: Under the unamended Wealth-tax Act, 1957, a contingent or inchoate right to receive enhanced compensation, while the amount remains disputed and uncertain, does not constitute an asset forming part of net wealth.