Annual ratable value must follow standard rent under rent control law, not actual rent, and estoppel cannot override statute.

Annual ratable value for property tax must be assessed by the rent the building may reasonably fetch under the governing rent control law, not by actual contractual rent where that rent exceeds the lawful ceiling. The assessable value is therefore capped by the standard rent determinable under the statute, and the authority must independently ascertain that figure. A private admission by the owner that tax may be paid on actual rent does not create estoppel against the statutory method of assessment, because statutory rights and obligations cannot be displaced by concession. The assessment based on actual rent is unsustainable and must be recomputed under the statutory measure of standard rent.

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Issues: (i) Whether the annual ratable value of a building is to be determined on the basis of the actual rent received from the tenant or on the basis of the standard rent reasonably expected under the rent control law. (ii) Whether an admission by the owner that tax may be paid on the basis of actual rent creates an estoppel against claiming the statutory mode of assessment.

Issue (i): Whether the annual ratable value of a building is to be determined on the basis of the actual rent received from the tenant or on the basis of the standard rent reasonably expected under the rent control law.

Analysis: The statutory expression governing annual value requires the authority to assess the rent at which the property may reasonably be expected to let from year to year. The settled principle applied by the Court is that actual contractual rent is not the governing measure where rent control law limits the rent lawfully recoverable. The assessable value is capped by the standard rent determinable under the relevant rent legislation, and the authority must independently ascertain that figure on recognized principles rather than adopt the actual rent received.

Conclusion: The annual ratable value cannot be based on actual rent and must be determined with reference to the standard rent reasonably expected under the statute, in favour of the assessee.

Issue (ii): Whether an admission by the owner that tax may be paid on the basis of actual rent creates an estoppel against claiming the statutory mode of assessment.

Analysis: A private admission cannot override a statutory mandate. Where the law prescribes the manner of determining annual value, the assessing authority is bound to follow that method. A mistaken concession by the owner does not authorize assessment contrary to the statute, because there can be no estoppel against statutory rights and obligations.

Conclusion: No estoppel arose from the admission, and the statutory method of assessment remained controlling, in favour of the assessee.

Final Conclusion: The assessment based on actual rent was unsustainable, and the authorities were required to recompute annual value and tax in accordance with the statutory measure of standard rent.

Ratio Decidendi: For property tax purposes, annual value must be determined by the rent the property may reasonably fetch under the governing rent control law, not by actual contractual rent, and statutory assessment cannot be displaced by estoppel arising from an erroneous admission.

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