Post-year inspection reports may support earlier agricultural income assessments if adjusted for passage-of-time effects.

An inspection report obtained after the close of the previous year may be relied on for assessing earlier-year agricultural income, because the statutory scheme allows post-year material to be used as relevant evidence on yield, cultivation expenses, rent and collection charges. The later findings are not an absolute bar; they must be adjusted to reflect the state of the holding in the earlier year, including effects of growth, deterioration or lapse of time. On the facts, the assessing authority made the necessary allowances, so the challenge to use of the later inspection report failed and the prior-year assessments were upheld.

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Issues: Whether the findings recorded in an inspection of agricultural holdings made after the relevant previous year could be used for completing assessments for earlier years.

Analysis: The charge under the Act is on the agricultural income of the previous year, and the assessment machinery permits an inspection or commission report to be obtained during the pendency of assessment proceedings or in appeal. Such a report is necessarily ex post facto in relation to the previous year, but the statutory scheme makes it relevant material for determining yield, cultivation expenses, rent, and collection charges. The earlier inspection-related observations in the cited precedent did not lay down an absolute bar; they only indicated that the later inspection findings must be adjusted to the state of affairs existing in the earlier year, having regard to growth, deterioration, or other passage-of-time effects. On the facts, the assessing authority made the necessary allowances.

Conclusion: The inspection findings could validly be used for the earlier assessment years, subject to appropriate adjustment for the passage of time, and the challenge failed.

Final Conclusion: The writ petition was rejected because no illegality was shown in using the later inspection report to complete the prior-year agricultural income assessments.

Ratio Decidendi: An inspection report obtained after the close of the previous year may be relied upon in assessing that year's agricultural income, provided the findings are suitably adjusted to reflect the earlier state of the holding.

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