Enhanced compensation pending appeal is not a realisable wealth-tax asset, but final acquisition judgments must be applied in reassessment.

Enhanced compensation claimed in land acquisition proceedings was treated as not accruing as a realisable asset for wealth-tax until finally determined, because a pending appeal leaves the claim uncertain on the valuation date. However, where a later final judgment materially alters the compensation position, the assessment must be recomputed to reflect that adjudication. The Wealth-tax Officer was therefore required to give effect to the subsequent High Court judgment and amend the relevant assessments; the appellate direction to that effect was upheld.

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Issues: Whether enhanced compensation pending final determination in land acquisition proceedings could be treated as an asset for wealth-tax purposes, and whether the Wealth-tax Officer was bound to amend the assessments in light of the subsequent High Court judgment in the acquisition appeal.

Analysis: Enhanced compensation does not accrue or arise as a real asset until it is finally accepted or determined by the court of last resort. Pending appeal, the claim remains uncertain and cannot ordinarily be brought to wealth-tax as an existing asset on the valuation date. However, where a subsequent final judgment in the land acquisition matter has materially altered the compensation position, the assessment authorities must give effect to that judgment and recompute the net wealth accordingly.

Conclusion: The Court held that the Wealth-tax Officer must give effect to the subsequent High Court judgment and recalculate the assessments for the relevant years. The direction of the Appellate Assistant Commissioner, as affirmed by the Tribunal, was upheld, and the question referred was answered in the affirmative.

Ratio Decidendi: A claim for enhanced compensation under appeal is not a realisable asset for wealth-tax until finally determined, but subsequent final adjudication in the underlying acquisition proceedings must be applied while recomputing the assessment.

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