Urban land valuation remanded for fresh factual verification, while motor vehicles must be assessed at written down value.

Urban land claimed to form part of factory premises or business land was remanded for fresh factual verification because its location and character had not been properly examined, and the Revenue had not been given opportunity on the fresh material; the first appellate relief on that point was set aside for statistical purposes. Motor vehicles for wealth-tax purposes were correctly required to be valued at written down value under Schedule III, as depreciable business assets must be taken at the balance-sheet written down value on the valuation date, and that valuation direction was upheld.

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Issues: (i) Whether the land treated as urban land was excludible from net wealth as forming part of factory premises or land used for business, and whether the matter required further factual verification; (ii) Whether the value of motor vehicles for wealth-tax purposes had to be taken at written down value under the prescribed valuation rules.

Issue (i): Whether the land treated as urban land was excludible from net wealth as forming part of factory premises or land used for business, and whether the matter required further factual verification.

Analysis: The location and character of the land were not properly investigated at the assessment stage. The first appellate authority relied on material that had not been examined by the Assessing Officer and recorded a factual finding that the land formed part of the factory premises. Since the disputed factual position had to be verified from land records or spot inspection, and the Revenue had not been given opportunity in respect of the fresh material, the issue required reconsideration.

Conclusion: The issue was remanded to the Assessing Officer for fresh examination, and the relief granted by the first appellate authority on this point stood set aside for statistical purposes.

Issue (ii): Whether the value of motor vehicles for wealth-tax purposes had to be taken at written down value under the prescribed valuation rules.

Analysis: Wealth-tax valuation of assets has to be determined as on the valuation date in the manner laid down in Schedule III. For depreciable business assets, the prescribed rule requires adoption of the written down value reflected in the balance sheet. The first appellate authority correctly directed valuation of the vehicles on that basis.

Conclusion: The valuation directed by the first appellate authority was upheld and the Revenue failed on this issue.

Final Conclusion: The dispute was disposed of by remitting the land-in-wealth issue for fresh factual verification while sustaining the valuation of motor vehicles at written down value under the wealth-tax valuation rules.

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