Rent capitalisation valuation of immovable property includes land value, so no separate reversionary addition is permitted.

When immovable property is valued under the rent capitalisation method for wealth-tax purposes, the valuation is treated as a composite figure covering both land and building. The land component is already reflected in the capitalised rental value, so a separate addition for the reversionary value of the land would duplicate the same element. The reversionary value is therefore not includible over and above the rent capitalisation valuation, and the point is answered in favour of the assessee.

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Issues: Whether, when an immovable property is valued by the rent capitalisation method under the Wealth-tax Act, the reversionary value of the land can be separately added to the valuation.

Analysis: Valuation on a rental basis determines the composite value of the land and building. Once that method is adopted, the land value is already reflected in the capitalised rental valuation. Adding a separate reversionary value of the land would amount to duplicating the same component. The reasoning accords with the view that rent capitalisation covers the entire property value for valuation purposes.

Conclusion: The reversionary value of the land is not includible in addition to the rent capitalisation valuation. The question is answered in the affirmative and in favour of the assessee.

Ratio Decidendi: Where an immovable property is valued by the rent capitalisation method, the resulting valuation includes both land and building, and no further addition can be made towards the reversionary value of the land.

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