Present value governs remainderman valuation as discounted actuarial method was upheld for future corpus interest.

The remainderman's interest was valued on a discounted actuarial basis by treating the right to receive the corpus at a future uncertain date as its present worth, with the mother's life interest taken into account. In the absence of specific valuation rules, the appellate authority and the Tribunal applied an actuarial method that discounted the future receipt to present value. That approach was held to be correct because the value of a remainderman's interest must be computed on present value rather than the full future value of the property, and no referable question of law arose.

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Issues: Whether the Tribunal was right in upholding the valuation of the remainderman's interest on a discounted actuarial basis and whether any referable question of law arose from that decision.

Analysis: The valuation concerned the present worth of the assessee's right to receive the corpus at an uncertain future date, the life interest of the mother being a relevant factor. In the absence of specific valuation rules, the appellate authority and the Tribunal adopted an actuarial method that discounted the future receipt to present value. That approach was supported by the principle that the value of a remainderman's interest must be computed on the basis of present value and not on the full future value of the property.

Conclusion: The valuation method adopted by the appellate authority and affirmed by the Tribunal was correct, and no referable question of law arose.

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