Annual value includes tenant-paid municipal house tax as part of rent payable for property occupation.

Tenant-paid municipal house tax was treated as part of the annual value of property under the income-tax provision because annual value means the amount for which the property may reasonably be expected to let from year to year. The tenant's willingness to pay occupation charges, including sums meeting the landlord's statutory liability, was accepted as the best evidence of that amount, and no distinction was drawn between rent reserved directly and additional payments made on the landlord's behalf. Because the statute expressly allowed a deduction for land revenue, no implied deduction was recognised for municipal house tax, which remained includible in the rent payable to the landlord.

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Issues: Whether municipal house tax paid by a tenant on behalf of the landlord is to be included in determining the annual value of property under the income-tax law.

Analysis: The expression "annual value" was treated as the sum for which the property might reasonably be expected to let from year to year. The amount a tenant is willing to pay for occupation was held to be the strongest evidence of that sum, and no distinction was accepted between rent reserved directly and an additional sum the tenant agrees to pay towards a liability of the landlord. The Court held that the statutory definition in the income-tax provision controlled the inquiry, and that the landlord's municipal tax liability paid by the tenant formed part of the amount for which the property might reasonably be expected to let. The existence of an express deduction for land revenue was treated as indicating that no similar implied deduction could be made for municipal house tax.

Conclusion: The tenant-paid municipal house tax is includible in computing annual value and is to be treated as part of the rent payable to the landlord.

Ratio Decidendi: In determining annual value under the property income provision, all amounts forming part of the tenant's consideration for occupation, including sums paid towards the landlord's statutory liability, are included unless expressly excluded by the statute.

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